Office of the

Inspector General
Brian D. Lamkin

Review of Richland School District Two:

Operations, Fiscal Affairs, Human Capital and
Board of Trustees

Case# 2022-5841-I November 2022

 I. Introduction
The South Carolina Office of the State Inspector General (SIG) was established by the South Carolina General
Assembly in 2012 (Act No. 105) for the purpose of investigating and addressing allegations of fraud, waste,
abuse, mismanagement, misconduct in agencies, specifically the executive branch of state government.
The SIG’s authorities are found in South Carolina Code of Laws, §1-6-10 et seq. In 2022, the South Carolina
General Assembly passed S. 202 (Act No. 223) which expanded the SIG’s authority, with limitations (§1-6-35),
to investigate public schools and school districts, public charter schools and authorizers, and voluntary
associations that establish and enforce bylaws or rules for interscholastic sports competition for public
secondary schools.
On 6/22/22, South Carolina Governor Henry McMaster requested the SIG to conduct an investigation of the
Richland School District Two (District) and its Board of Trustees (Board) regarding allegations of potential
mismanagement, misconduct, and organizational or institutional dysfunction by the District’s elected and
appointed leadership.
The purpose of this report is to provide a road map for the District’s leadership and its Board to improve in its
delivery of quality education to its students in a unified effort. This investigation focused on the broader issues
confronting the District in the areas of operations, fiscal affairs, and human capital. The report is not intended
to address every individual complaint or issue conveyed to the SIG.

The SIG extends its appreciation to Superintendent Davis, District staff, and members of the Board of Trustees
for their cooperation and intentionality of seeking solutions to the issues identified by the SIG. The SIG also
extends its appreciation to current and former teachers and administrators, and to the parents and constituents in
the District for the candor, courage and valuable input provided to the SIG during this investigation.

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 Table of Contents

Page

I. Introduction…………………………………………………………………………………….. 1

II. Background…………………………………………………………………………………….. 4
A. Predicate
B. Scope and Objectives
C. Methodology
D. Richland School District Two
E. Board of Trustees

III. District Operations...…………………………………………………………………………… 5

A. Strategic Plan
B. District Report Card
C. Delivery of Special Education Instruction
D. District – Community Relations
E. Student Disciplinary Procedures
F. Findings and Recommendations – District Operations

IV. Fiscal Affairs…………………………………………………………………………………… 12

A. District Procurement Code
B. District Procurement Cards
C. Human Resources Department Checkbook
D. Richland School District Two Foundation
E. Findings and Recommendations – Fiscal Affairs

V. Human Capital…………………………………………………………………………………. 20
A. District Staffing
B. Premier 100 Initiative
C. Human Resources Processes
D. Investigative Process for Employee Misconduct Matters
E. Findings and Recommendations – Human Capital

VI. Board of Trustees………………………………………………………………………………. 29

A. Board Decorum and Dysfunction
1. Consultant assessment of Board members
B. Board Oversight and Roles
C. Surreptitious Recording of Board Executive Session – 4/28/22
D. Board – Superintendent Relationship
1. No contact directive issued to Lashonda McFadden
E. Board – District Staff Relationship
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 1. 9/24/21 Board meeting
2. 10/25/22 Board Meeting
F. Board Financial Matters
1. Board member travel budget allocations
2. Board member travel advances
3. Circumvention of financial internal controls – Lashonda McFadden
G. Board Transparency – Circumvention of FOIA
1. Use of Personal Email – Board Business
2. Use of Personal Cell Phone – Board and District Business
H. Board – Community Relationship
1. Taking the Oath of Office prior to filing Statement of Economic Interest
2. Public participation at Board meetings
3. Trespass Notice – Removal from public participation
4. Lack of transparency in Board communications
I. Summary of Individual Board Members
1. Mrs. Lashonda McFadden
2. Dr. Monica E. Scott
3. Mrs. Amelia McKie
4. Dr. Teresa Holmes
5. Mr. James Manning
6. Dr. Cheryl Caution-Parker
7. Mrs. Lindsay Agostini
J. Findings and Recommendations – Board of Trustees

VII. Conclusion……………………………………………………………………………………... 47

Compilation of Findings and Recommendations………………………………………….. 48

List of Appendices…………………………………………………………………………. 53
District and Board Response

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 II. Background
A. Predicate
By letter dated 6/22/22, South Carolina Governor Henry McMaster requested the Office of the State Inspector
General (SIG) to initiate and conduct an investigation, review, and analysis of Richland School District Two
(District) in connection with various allegations and concerns regarding potential mismanagement, misconduct,
violations of state or federal law, or wrongdoing. 1 Specifically, parents and constituents relayed various
complaints and communicated allegations reflecting organizational or institutional dysfunction by the District’s
elected and appointed leadership. (See Appendix A)

B. Scope and Objectives

The scope of the District investigation covered the period of 7/1/18 – 6/30/22, and examined the effectiveness
and efficiency of District operations, fiscal affairs, and human capital. In addition, the investigation focused on
the District’s Board of Trustees (Board) for leadership-related matters that negatively affected the District’s
ability to conduct, manage, and oversee its affairs in an appropriate and effective manner. The period of review
for the Board covered the period of 7/1/18 through the public release date of this report on 11/3/22.

C. Methodology
The SIG reviewed relevant documentation comprised of reports, financial records, emails, and text messages
that encompassed 85,814 files and 19.4 gigabytes of information provided in discovery by the District, the
Richland School District Two Foundation, and other non-District entities.

The SIG conducted more than 90 interviews of District staff and Board members under oath, members of the
public, subject matter experts, and persons who initiated confidential contact with the SIG. In addition, the SIG
reviewed applicable state and federal laws, regulations, and policies.

Reviews and investigations by the SIG are conducted in accordance with professional standards set forth by the
Association of Inspectors General’s Principles and Standards for Offices of Inspector General, often referred to
as the “Green Book.” This investigation used the preponderance of evidence standard.

D. Richland School District Two

The District provided a broad range of general and specialized educational services and instruction for students
in pre-kindergarten through grade twelve in 20 elementary schools, seven middle schools, five high schools,
four magnet centers, one child development center, one alternative school in Richland County, and the W. R.
Rogers Adult Education and R2i2 Student Innovation Centers. The District received funding through state
appropriations, federal government programs and its local tax base. During the 2021-22 school year, the Day-
45 enrollment for the District was 28,349 students, 55.6% of whom were pupils in poverty.

Dr. Baron R. Davis began his term as District superintendent on 7/1/17. For the 2022-23 school year, Dr. Davis
supervised 4,793 staff, including 2,081 certified teachers and 2,712 administrative and support staff.

1
Pursuant to Act No. 223 (SC Code of Laws §1-6-35) the Governor may request the Inspector General to investigate a public school
district.
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 E. Board of Trustees

The District was governed by a Board of Trustees (Board) comprised of seven (7) at-large members elected to
four-year terms. Following the November 2020 election during the 2020-21 school year, the Board was
constituted as follows:

Trustee Term
Mrs. Lindsay Agostini 2016-2020; 2020-2024
Dr. Cheryl Caution-Parker, Ed. D.* 2014-2018; 2018-2022
Dr. Teresa Holmes, Ed. S., Ed. D. 2018-2022
Mr. James Manning * 2010-2014; 2014-2018; 2018-2022
Mrs. Lashonda McFadden 2020-2024
Mrs. Amelia McKie * 2014-2018; 2018-2022
Dr. Monica Scott, Ed. D. 2012-2016; 2016-2020; 2020-2024
(*) Not running for re-election at the end of the term of office in November 2022

Dr. Teresa Holmes was Board chair for the 2020-21 school year. Mr. James Manning succeeded Dr. Holmes as
Board chair for the 2022-23 school year beginning on 7/1/22.

III. District Operations

Examination of District operations concerned the delivery of academic instruction to students and related
matters.

A. Strategic Plan

The District’s “Pathway to Premier” was the strategic plan for the 2021-22 school year. The strategic plan was
prepared by staff and presented to the Board for review and approval in 2018.

Pathway to Premier consisted of achievement, talent, and culture and environment goals for student outcomes,
staff outcomes, and community outcomes. The goals centered on the District’s core values of learning,
character, community, and joy. Examples of these goals are set forth below:

• Achievement goal for learning: “Richland Two will work to ensure success for all partners by
preparing them for their futures.”
• Student outcomes goal: “Our students perform among the highest scorers in the nation on key
measures of success.”
• Staff outcomes goal: “Our staff participates in on-going, relevant professional learning
experiences.”
• Community outcomes goal: “We collaborate with our partners to provide learning opportunities
for community members.”

The remaining goals and outcomes for achievement, talent, and culture and environment within the areas of
learning, character, community, and joy were similar in format as the achievement goal for learning. Best
practices for the creation of strategic plans recommend that goals and objectives/outcomes be specific,
measurable, attainable, relevant, and time bound (SMART). While the goals and objectives were broadly
defined and aspirational, the SIG assessed that the goals contained in the strategic plan were neither specific,
measurable, nor time bound. (See Appendix B)

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The District advised the SIG it has initiated a comprehensive development on the next five-year strategic plan in
collaboration with Scholar First, Inc. that includes SMART goals. This endeavor encompasses the following
teams:

• District Planning Team meets twice a month and makes high-level decisions on strategic
planning strategies. It is comprised of the District’s senior leadership and chiefs along with
school principal representatives.
• District Leadership Team refines the vision and goals of the District Planning Team and includes
teacher representatives.
• Core Planning Team is a broad group of 40 individuals that meets monthly and provides ongoing
feedback and input on the strategic planning process. The team is comprised of students,
parents, community partners, classified staff, District leadership and academic representatives.
• Instruction Planning Team
• Student Advisory Group

B. District Report Card

The Every Student Succeeds Act requires state education agencies, e.g., the South Carolina Department of
Education (SCDE), to prepare and disseminate an annual state report and local education agency report card
that meet the minimum requirements prescribed in federal law. The report cards provide information about
each school and district, including test performance, teacher qualifications, student safety, awards, and parental
involvement.
On 3/26/21, the U.S. Department of Education waived federal accountability requirements and granted
flexibility in administering assessments due to COVID-19. As a result, some data may be missing. For the
2021-22 school year, the District’s report card reflected the following overall student performance in academic
achievement, compared to the state average:

State
Overall Student Performance District Average
SC Ready English Language Arts (Reading and Writing) 49.4% 46.6%
(percent met or exceeded)
SC Ready Mathematics (percent met or exceeded) 40.5% 38.9%

End-of-Course Assessment Results in English 1 54.2% 57.9%

(scoring C or higher)
End-of-Course Assessment Results in Algebra 1 46.1% 44.2%
(scoring C or higher)

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The on-time graduation rate for the District for the 2021-22 school year was 85.1%, which exceeded the state
average of 83.8% though it steadily declined to the lowest graduation rate of the four-year period. The
District’s four-year cohort graduation rate was:
District Four-Year Cohort Graduation Rate
Comparison 2019 2020 2021 2022
Richland Two 88.9% 88.8% 86.6% 85.1%
State 81.1% 82.2% 83.3% 83.8%

On 9/6/22, the SCDE released the results of the spring 2022 SCPASS and SCREADY assessments. SCPASS is
the state science test and is administered in grades 4 and 6. SCREADY is given to students in grades 3 – 8 in
English Language Arts (ELA) and math.
The tables below provide a summary of the District’s student performance compared to the state averages for
the last three school years that SCPASS, SCREADY, and EOCEP assessments were conducted. State testing
was not conducted for the 2019-20 school year due to COVID-19 school closures.
For illustrative purposes, the SIG utilized a color-coded system to identify year-over-year trends in student
achievements for the District. The color-coded key utilized is described as follows:
GREEN: Increase over 2020-21 and 2018-19 (Pre-Pandemic)
YELLOW: Increase over 2020-21 but a decrease from 2018-19 (Pre-Pandemic)
RED: Decrease from 2020-21 and 2018-19 (Pre-Pandemic)

Table 1. Percent of Students Scoring Met or Exceeded Expectations on SCPASS Science

4th Grade 6th Grade
Year District State District State
2019 51.1 52 47 47.2
2021 40.8 43.7 39.5 42.1
2022 52.5 46.4 47.1 45.6

Table 2. Percent of Students Scoring Met or Exceeded Expectations on SCREADY ELA

3rd Grade 4th Grade 5th Grade 6th Grade 7th Grade 8th Grade
Year District State District State District State District State District State District State
2019 51.1 49.7 53.6 51.2 44.3 41 44.9 41 47 44 48.4 44.6
2021 42.3 43.3 41.1 46.1 36.4 38.9 42.8 41.8 49.3 42.5 45.8 41.9
2022 49.6 48 55.6 50.4 52.3 48.3 45 45.1 44.9 43.2 50.2 45.9

Table 3. Percent of Students Scoring Met or Exceeded Expectations on SCREADY Math

3rd Grade 4th Grade 5th Grade 6th Grade 7th Grade 8th Grade
Year District State District State District State District State District State District State
2019 62.1 57.7 53.4 50.5 51.1 45.4 45.2 43.9 32.3 35.5 39.9 36.6
2021 42.7 46.9 39.6 42 34.6 38.1 28.8 33.9 29.7 30.4 21.9 30.7
2022 54 51 45.8 43.1 46.7 43.3 36.3 35.7 29.3 30.9 31.3 30.2

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The SIG noted the District’s SCPASS and SCREADY assessments demonstrated that students in grades four
through six and the eighth grade had rebounded to pre-pandemic achievement levels in ELA and Science
against a national backdrop of falling scores. The ELA and Science scores exceeded the state averages for all
grade levels except the sixth grade (ELA). Math skills, which are difficult to learn through online teaching, did
not reach pre-pandemic levels but exceeded state averages in five of the six grades tested.
The SCDE released the End of Course Examination Program (EOCEP) assessments on 9/19/22 for the 2021-22
school year. The EOCEP is the state-mandated end of course examination for Algebra 1, Biology, English 2,
and U.S. History courses. The EOCEP score, except for U.S. History, constitutes 20% of the student’s final
grade per state law. The following table provides a summary of the District’s student performance for the last
three years of EOCEP assessments:
Table 4. Percent of Students Passing on the EOCEP Assessments

Algebra 1 Biology English 2 US History

Year District State District State District State District State
2019 74.1 68.6 70.3 67.2 78.8 79 67.5 66.9
2021 65.3 61.5 56.9 57.3 85.7 83.5 53.5 58.2
2022* 67.3 65.9 53.9 57.4 85.8 84.3 50.3 56.5
*U.S. History was a field test and did not count towards 20% of the students’ final grade.

On 9/19/22, the SCDE released the results of the 2021-22 school year WorkKeys assessment. WorkKeys is the
state-mandated career readiness assessment given to all third-year high school students in three areas: Applied
Math, Graphic Literacy and Workplace Documents. The new WorkKeys assessment was administered for the
first time in 2021-22 school year. Based on how students scored on each section, they received an overall
certificate if their scores qualified. The District achieved approximately the same percentage of students
earning a certificate, as did students statewide.

Table 5. 2021-22 School Year - Percent of Students by Certificate Level- WorkKeys

Platinum Gold Silver Bronze No Certificate
District 11.3 13 26.5 28.8 20.5
State 11.3 15.5 25.7 27.2 20.3

C. Delivery of Special Education Instruction

Special Education (SPED) instruction is delivered to qualified students in accordance with an individualized
education program (IEP) plan and/or a “504 plan.” An IEP is a legal document created pursuant to the
Individuals with Disabilities Education Act (IDEA) that ensures students with a learning disability are provided
with a Free Appropriate Public Education (FAPE). Parents of qualified students, together with school district
officials, create the IEP plan of specialized instruction and related services for the student.
Section 504 plans are created for qualified students pursuant to Section 504 of the Rehabilitation Act of 1973 to
protect the rights of individuals with physical disabilities in programs and activities that receive federal
financial assistance from the U.S. Department of Education.

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The SIG determined the District served more than 3,700 SPED students on average for the school years of
2018-19 through 2021-22 as follows:
• October 2018 = child count of 3,740
• October 2019 = child count of 3,816
• October 2020 = child count of 3,690
• October 2021 = child count of 3,747
The SIG determined the SCDE received thirteen complaints over the four-year period concerning the delivery
of SPED instructional services by the District. These complaints were investigated by SCDE.
Blythewood Academy and SPED instruction staffing
Blythewood Academy is a District alternative school where students are assigned up to 45 days to receive
remedial education due to their removal from their District-assigned school for disruptive behavior. During the
2021-22 school year, two math teachers and one science teacher were reassigned to E.L. Wright Middle School
and one business education teacher was assigned to Richland Northeast High School. In addition, in November
2021 a teacher and a teacher’s aide were injured during a student altercation and unable to return to work.
These positions remained vacant for the remainder of 2021-22 school year.
As a result, at least one class of students at Blythewood Academy received remote instruction via iTutor from
November 2021 through the end of the school year while monitored by a non-certified staff member. Many of
these students were covered by an IEP plan, and concerns were raised that the SPED instruction received by
these students was insufficient due to the lack of in-person SPED teachers. When the delivery of special
education instruction is deficient with respect to the IEP, the students should be provided with compensatory
education, provided by the District at its expense. 2
In January 2020, the District received a consultant’s report [A Review of Instructional Services and Supports for
Richland School District Two] that addressed instructional services with a particular emphasis on special
education. The consultant found high attrition among SPED teachers, many of whom cited recurring challenges
and difficulty with discipline/challenging behaviors and lack of administrative support. The consultant issued
70 recommendations based on findings, which included:

• Discrepancies existed between the specialists’ official job descriptions and assigned
duties/responsibilities.
• Administrators in the Instructional and Supports Department expressed concern over the inability
of not providing the level of support requested by principals and special education teachers
related to curriculum and instruction in the SPED classroom.
• SPED caseloads revealed significant discrepancies and inconsistencies in numbers of students
assigned to teachers.
• SPED teachers were concerned principals did not consistently administer discipline to students
and that disciplinary consequences were not consistent with the nature and severity of the
infraction.
• SPED teachers used 36 different interventions/programs, which the consultant deemed an
impossible number of programs to support and monitor.

2
Bd. of Education of Oak Park & River Forest High School District 200 v. Toff, 79 F3rd 654 (7th Cir., 1996).
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 • Numbers of SPED students in classrooms varied significantly, with some numbers being too
high for effective instruction to occur based on the severity and nature of the behaviors exhibited
by the students.
The SIG verified the District initiated a reorganization of the SPED program management under a single
authority that included an increase in SPED staffing. In addition, the SIG identified that none of the thirteen
SPED complaints investigated by the SCDE related to the Blythewood Academy.
D. District – Community Relations
Transparency – Public access to District library catalog
On 11/17/21, the District instructed media coordinators throughout the District to remove guest access to library
catalogs “as soon as possible.” The 11/17/21 email read as follows:
“Considering the political climate and scrutiny of school library collections, [name omitted],
Richland two’s Chief Academic Officer, has asked that we remove guest access to prevent
access by anyone outside of Richland Two who may have malicious intent in searching our
library collections.”
A well-respected First Amendment attorney opined that removal of guest access was a reasonable exercise of
discretion and governance by the District administration, particularly because the information sought by
taxpayers and others was available through the Freedom of Information Act (FOIA). Parents retained access to
the catalogs through their child’s student account.
The SIG concurs that District parents retained online access to the school library catalog through their child’s
student account and that access to the school library contents remained available to the public through FOIA.
Unfortunately, the distribution of the 11/17/21 email unnecessarily subjected the District to criticism about a
lack of transparency and intent of persons searching the District’s library collections. The SIG found no
evidence of “malicious intent” as described in the District email directing school media specialists to remove
guest access to school library catalogs.
Toolkit for Concerned Parents
The superintendent and other senior staff referenced a “playbook” used by members of the public to disrupt
public board meetings and collaborate with certain Board members to impede the business operations of the
District. The superintendent provided the Manhattan Institute’s Woke Schooling: A Toolkit for Concerned
Parents as evidence that a playbook literally existed.
The “Toolkit” raised concerns about “critical pedagogy” found in some public and private schools that involved
concepts of addressing white supremacy and racism. Parents were encouraged to become more involved in
their children’s education, to organize and respond to objectionable practices as a group, to offer a positive
vision, and to take legal action where necessary.
The SIG’s review found that the practices advocated in the “Toolkit” were a legitimate exercise of First
Amendment rights involving the responsibilities of parents.

E. Student Disciplinary Procedures

District officials stated that principals primarily address student discipline through a student discipline
matrix/table to promote consistency and fairness. Student discipline was governed by District policies and
related administrative rules that included:

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 Table A
District Policy Administrative Rule SC Code of Laws
Policy JI Student Rights AR JI-R Student Rights Title 59 – Education
and Responsibilities and Responsibilities
Policy JICDA Code of AR JICDA-R Section 59-19-90(3) - General powers and duties of school trustees -
Conduct Code of Conduct regulation of student conduct.
(Levels I-III)
Sections 59-63-210 through 280 - Grounds for which trustees may expel,
suspend, or transfer pupils.

Section 59-63-370 Student’s conviction or delinquency adjudication for

certain offenses
Policy JICI Weapons in Section 16-23-420 - Possession of firearm on school property; concealed
Schools weapons.

Section 16-23-430 - Concealed weapons, school property exception.

Section 59-63-235 - Expulsion of student determined to have brought

firearm to school.

Section 59-63-370 - Definition of a weapon.

Policy JIH “Student AR JIH-R Section 59-24-60 - Requires administrators to contact law enforcement.
Interrogations, Student Interrogations
Searches, and Arrests and Searches Section 59-63-1110, et seq. - Search of persons and effects on school
property.

Policy JKE Policy JKE AR JKE-R Section 59-19-90(3) - General powers and duties of school trustees to
Expulsion of Students Expulsion of Students prescribe standards of conduct and the suspension or permanent
dismissal of students.

Section 59-63-210 - Grounds for suspension, expulsion, or transfer

Section 59-63-235 - Expulsion of student determined to have brought a

firearm to school.

Section 59-63-240 - Expulsion hearings - times, procedures, and appeals.

The District’s “discipline task force” created a discipline guidelines table and published it to District staff by
Pupil Services. Appeals of adverse rulings, primarily those resulting in expulsion or reassignment to the
alternative school, may be appealed to the District’s hearing officer. An adverse ruling by the hearing officer
may be appealed to the Board.

As set forth in Table A, the District policies governing student discipline are consistent with the SC Code of
Laws that address student discipline matters, to include expulsion hearings, procedural matters, appeals, and
general powers and duties of school trustees. The SIG, however, did not identify where the discipline
guidelines table was incorporated into a District administrative rule or Board policy. The SIG recommends that
the student discipline table be incorporated into an existing District administrative rule.

F. Findings and Recommendations – District Operations

Finding #DO-1: The District’s five-year strategic plan that included the 2021-22 school year contained goals
that were neither specific, measurable, nor time bound. The SIG determined the District initiated a
comprehensive strategic planning process for the new five-year strategic plan set to commence with the 2023-
24 school year that will address specific goals and measurable outcomes. No further action recommended.
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Finding #DO-2: The District did not identify a District administrative rule or Board policy adopting the
student discipline guidelines table.
Recommendation #DO-2: The SIG recommends that a student discipline table be incorporated into an
existing District administrative rule or Board policy.

IV. Fiscal Affairs

A. District Procurement Code
South Carolina Code of Laws §11-35-5340 provides that school districts whose budget of total expenditures
exceed $75 million annually is subject to the Consolidated Procurement Code (CPC), except that:
“… if a District has its own procurement code which is, in the written opinion of the Division
of Procurement Services of the State Fiscal Accountability Authority, substantially similar to
the provisions of the South Carolina Consolidated Procurement Code, the District is exempt
from the provisions of the South Carolina Consolidated Procurement Code….”
The District provided the SIG a procurement code it adopted in 2006. Neither the State Fiscal Accountability
Authority’s Division of Procurement Services (DPS) nor the District were able to identify a written opinion
from the DPS exempting the District from the CPC in favor of the District’s procurement code as required by
SC Code of Laws, §11-35-5340. (See Appendix C)
The SIG determined the District failed to comply with South Carolina Code of Laws §11-35-5340 by not
having a written opinion from the Division of Procurement Services for its procurement code. Per the DPS
website, 25 large school districts have adopted the 2021 Model School District Procurement Code except for the
District. (See Appendix D)
Procurement process regarding the District’s custodial services contract
The District published an advertisement on the South Carolina Business Opportunities website on 3/24/22 to
solicit proposals from qualified vendors for custodial services. On 5/4/22, SSC Services for Education
(“Service Solutions”), the District’s contractor for custodial services for over two decades, submitted its
proposal in response to the District’s request for proposal (RFP). (See Appendix E)
Service Solutions’ proposal included the following statements:
• In support of the Premier 100 Initiative at Richland Two, SSC will donate $15,000 annually
to aid in the strategic recruitment and retention of minority male teachers. At the Premier
100 Summit this November, all men of color educators hired at Richland Two this year will
receive $250. All retained Premier 100 men of color who renew their contracts with the
district will receive $200. The remaining funds will be used for future hires, recruiting
events, and the next Premier 100 Conference recruiting event in March.

• Over the past five years we have contributed $125,000 to the betterment of the community
through the Richland School District Two. In the new contract the financial time and
resource support that has empowered and improved the district will continue.
Service Solutions pledged to make scholarship donations in the amount of $25,000 annually, a total of $125,000
for the life of contract, and $15,000 annually to Premier 100, a total of $75,000 for the life of the contract. The
District awarded Service Solutions the custodial contract with an annual base value of $9,762,192.
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South Carolina Code of Regulations §19–445.2165 (A) and (B) states:
(A) “It is the policy of the State that a governmental body should not accept or solicit a gift,
directly or indirectly, from a donor if the governmental body has reason to believe the donor
has or is seeking to obtain contractual or other business or financial relationships with the
governmental body.”
(B) “Prior to accepting a gift, care should be taken to determine whether acceptance of the
gift will provide the donor, directly or indirectly, an undue competitive advantage in
subsequent procurements.”
The SIG determined that the District did not comply with the South Carolina Code of Regulations §19–
445.2165 (A) and (B) when it executed a contract with Service Solutions after receiving the promise of gifts.
In mitigation, the SIG determined the District adhered to its own internal procurement code, in that:
• The District used a competitive sealed proposal.
• The District published the RFP notice through the District’s e-procurement site.
• Proposals were opened publically.
• The District followed its procurement guidelines for scoring and ranking.

B. District Procurement Cards

The District failed to provide the SIG a procurement card policy. Instead, the District provided its Financial
Operations Procedure Manual (finance manual) that included a section titled “District Procurement Card.” (See
Appendix F)
The District’s finance manual defined a procurement card (P-Card) as “a form of district regulated charge card
that allows goods and services to be procured without using the traditional purchasing process.” The SIG noted
purchasing limits for District P-Cards were not listed in the District’s finance manual, which did not comply
with the District’s procurement code. The District did not identify a central procedure for monthly review,
approval, and reconciliation of P-Card statements. Instead, each school conducted, if at all, separate reviews of
P-Card statements.
As of 6/30/21, the District had 198 P-Cards issued. 3 The SIG reviewed the District’s P-Card reports listed on
its website for fiscal years (FY) 2017-18 through 2021-22. The SIG analyzed a sample of 58 P-Card
transactions for approvals and the nature of the purchase and vendor. The District’s online accounting system
captures the account code for the expenditure, not on the supporting document.
The SIG determined items 1, 3, 4, and 5 did not have sufficient information to support the approval of the P-
Card expenditures. Item 7 was determined to be for Board member travel and did not require an out-of-state
travel approval form. Items 2 and 6 did not comply with the finance manual’s section entitled “State Contract
Purchases” as those purchases were for copy paper and office supplies.

3
Source: Audit work papers for the District’s 2020-21 annual audit.
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 Table B
Richland School District Two
Purchasing Card Transaction Review
Item Vendor Date Transaction Review Summary Issue
No. Amount
1 Williams & Sonoma 3/14/2019 $116.56 Merchandise Lacked item description and
purpose
2 Quill office supplies 4/29/2019 $200.82 Copy paper Improper use of P-Card and
vendor, item under state term
contract
3 Baltimore Orioles 5/22/2019 $72.60 Tickets No further information on purpose
4 Patriots Park 5/22/2019 $130.00 Admissions No further information on purpose
5 Lulu lemon 8/19/2019 $873.12 Clothing Lacked description and purpose
6 Quill 12/16/2019 $712.68 Office supplies Improper use of P-Card and
vendor, item under state term
contract
7 Marriott Marquis- 2/4/2020 $927.64 Conference travel Lacked out-of-state travel approval
Washington, DC document*
8 SC Gov 8/14/2020 $18,336.00 Engineering Approved by Will Anderson
services
9 HAPPEO OY 1/21/2022 $91,979.00 Software Improper use of P-Card
10 MIT Sloan MGT 1/12/2022 $7,560.00 Executive training Approved
(*) Board member travel – approval document is not required

The SIG noted the District had a P-Card issued under the name of “Accounts Payable” with a limit of $225,000
as of 7/27/22. The District used the accounts payable P-Card for recurring monthly bills such as cellular phones
and utility bills, as well as a foreign purchase of software for $91,979 as demonstrated in Table B (Item 9).
Large purchases should require a procurement process involving, at a minimum, the use of purchase orders and
a documented approval process. Recurring purchases, such as cellular phone bills and utility payments, should
be processed through accounts payable.
The SIG determined the District did not have a P-Card policy. P-Card usage is an area susceptible to fraud, and
strict controls should be in place to mitigate risk. Best practices for financial management establish limits for P-
Card expenditures, restrictions on the type of vendors for which a P-Card may be used, restrictions on the
number of P-Cards issued, and monthly reviews and reconciliation.

C. Human Resources Department Checkbook

The SIG identified a District checkbook was maintained by the Human Resources (HR) department for the
payment of SLED background checks. The account maintained a maximum balance of $500. The
administrative assistant maintained the checkbook in a locked file cabinet. The signatories on the HR
checkbook account included the HR senior chief and the HR executive director, which did not comply with
District policies DGA and DK in that only the superintendent and the chief financial officer are “authorized
signatures” on accounts payable checks.
• Policy DGA “Authorized Signatures,” states “The superintendent and chief financial officer are
authorized to sign payroll checks and accounts payable checks.”
• Policy DK “Payment Procedures,” states, “The district will make all payments for goods and
services only... against invoices, properly supported by authorized purchase orders, or
purchased using an authorized district procurement card against properly submitted vouchers
covering authorized expenses.”

14
The SIG further determined the check distribution process lacked external reconciliation and other internal
control deficiencies. When this matter was brought to the attention of the District leadership the checkbook was
removed from the HR department and the account was closed.

D. Richland School District Two Foundation

The Richland School District Two Foundation (Foundation) was a 501(c)(3) nonprofit corporation established
on 8/1/2000. The District’s website provided that the Foundation’s objective was to “raise funds and promote
educational programs for the district by soliciting and accepting donations from business groups, individual
corporations, foundations and individuals-at-large. A community board, whose members serve one to three
year terms, governs the foundation.”
The Foundation’s Articles of Incorporation filed with the South Carolina Secretary of State (SOS) on 8/1/2000
included the following information about the Foundation: (See Appendix G)
• The Registered Agent was Stephen W. Hefner. 4
• The nonprofit corporation was a public benefit corporation.
• The Foundation would not have members. The Foundation’s by-laws also stated the Foundation
“shall have no members.”
• The address of the principal office of the nonprofit corporation was 6831 Brookfield Road,
Columbia, SC 29206.5
• The remaining assets of the corporation were to be distributed to the schools in Richland School
District Two.
The Foundation’s most recent Form 990 [2020] filed with the Internal Revenue Service (IRS) stated that the
Foundation’s mission was “To raise and promote educational programs for Richland School District Two.”
The Foundation’s by-laws indicated the Foundation would operate under the name “Richland School District
Two Education Foundation,” which was inconsistent with the name [Richland School District Two Foundation]
listed on the IRS’s tax determination letter nor did it agree with the Foundation’s Articles of Incorporation filing
with the SOS. The District was unable to identify a Memorandum of Understanding (MOU) or other operating
agreement between the District and the Foundation that governed the use of District resources and personnel.
Checks payable to the District but deposited in a Foundation bank account
The SIG identified at least 35 checks ($138,575.44) made payable to the District that were deposited into a
Foundation bank account. In addition, District staff and equipment were used to make deposits and transfer
requests from the District.
The SIG determined that deficiencies in internal controls allowed District funds to be diverted to the Foundation
when checks made payable to the District were deposited into a Foundation account.
Foundation acceptance of gifts from District vendors
The District announced in a news release published on the District’s website on 12/13/21, which included a
picture of the superintendent, that:
• Service Solutions, the district’s custodial provider for almost a quarter of a century,
continues to strongly support initiatives in Richland School District Two. Service Solutions
4
On 5/15/15, the registered agent for the Foundation was changed to Harry W. Miley, the District’s Senior Chief Officer for Finance
& Operations.
5
District headquarters were located at 6831 Brookfield Road, Columbia, SC 29206 prior to re-locating to R2i2.
15
 has donated $15,000 to the PREMIER 100 Initiative. PREMIER 100 was created to
broaden the diversity of male teachers of color in the classroom. It is the district’s goal to
recruit and retain 100 minority male teachers by the year 2024.

• The generous donation from Service Solutions is providing new teachers recruited as part
of the PREMIER 100 initiative small monetary bonuses for entering the teaching
profession and for renewing their teaching contracts. Service Solutions has pledged
continued support of this initiative.
The SIG confirmed the $15,000 check was deposited into a Foundation bank account on 10/22/21. The
Foundation provided documentation to the SIG that indicated the deposit was made by District staff. On
11/5/21, the Foundation issued at least 49 checks 6 totaling $11,250 dollars to District employees in connection
with the District’s Premier 100 initiative.
The District did not confirm whether the bonuses or stipends paid to the Premier 100 cohorts were included as
income on the employees’ IRS Forms W-2 and whether the District withheld taxes from the income.
Diversion of District federal grant funds to a Foundation bank account
According to the District’s finance manual, “Richland School District Two is responsible for managing federal
awards with fidelity. The District is responsible for developing internal procedures to ensure effective
management of federal awards and compliance with the terms and conditions of the grant.”
District Policy DD stated, “All grants sought by the district will be coordinated through the director of grant
initiatives or the superintendent’s designee, reviewed by the chief financial officer, and approved by the
superintendent.”
The U.S. Department of Health and Human Services (HHS) awarded the District a five-year Drug-Free
Communities Grant that totaled $625,000 over a five-year period beginning in FY 2014-15 and ending in FY
2018-19.
According to the Notice of Award documents, “The Drug-Free Communities (DFC) Support Program was a
collaborative effort between the Office of National Drug Control Policy (ONDCP) and the Substance Abuse
and Mental Health Services Administration (SAMHSA).” The ONDCP issued grant awards to community
coalitions through an interagency agreement with SAMHSA.
Per the Drug-Free Communities Act of 1997, the purpose of DFC funding was to address two major goals: (1)
establish and strengthen collaboration among communities, public and private non-profit agencies, and federal,
state, local and tribal governments to support the efforts of community coalitions, and (2) reduce substance use
among youth and, over time, among adults.
The grant required the applicant to demonstrate, “that the coalition is an ongoing concern by demonstrating that
the coalition is a non-profit organization or has made arrangements with a legal entity eligible to receive
federal grants.” The grant also required a statement of legal eligibility and a signed Assurance of Legal
Eligibility or MOU between the applicant coalition and the grantee/legal applicant. On 2/24/14, the District
entered into a MOU with the Project Care Coalition (“Coalition”), not the Foundation. The superintendent at
that time and a representative for the Coalition executed the agreement.
The SIG confirmed with HHS that the District was awarded the DFC grant under the District’s federal employer
identification number (EIN). Additionally, the SIG confirmed through the HHS payment management system

6
The SIG determined only 49 checks cleared the Foundation’s bank account.
16
on 9/13/22, the bank account information for the DFC grant was updated on 4/28/15 (no further information
identified). As noted in Table C below, expense reimbursements claimed by the District were distributed by
automated clearinghouse (ACH) payments to the Foundation bank account at Wells Fargo Bank, N.A.,
following the bank account update on 4/28/15.
The SIG identified delays in repayments of the federal grant funds from the Foundation to the District. The
number of days lapsed between the Foundation’s receipt of HHS funds and date of the check transferring funds
from the Foundation to the District are illustrated in Table C.

Table C
Date Amount Date of Amount
Foundation Foundation Check from Check Foundation Days
received funds received from Foundation No. disbursed to Lapsed
from HHS HHS to District District
05/04/15 $ 37,328.71 06/22/15 1792 $ 37,328.71 49
06/24/15 $ 18,550.80 09/15/15 1798 $ 18,550.80 83
08/17/15 $ 22,083.82 09/15/15 1798 $ 22,083.82 29
09/16/15 $ 4,635.34 10/20/15 1808 $ 4,635.34 34
01/15/16 $ 26,831.72 02/17/16 1829 $ 26,831.72 33
03/23/16 $ 12,165.40 04/13/16 1834 $ 12,165.40 21
08/22/16 $ 72,723.87 09/26/16 1892 $ 72,723.87 35
10/17/16 $ 35,572.32 05/01/17 1915 $ 35,572.32 196
02/03/17 $ 26,884.16 05/01/17 1916 $ 26,884.16 87
04/18/17 $ 35,111.78 08/28/17 1977 $ 35,111.78 132
07/29/17 $ 44,939.76 08/28/17 1978 $ 44,939.76 30
11/06/17 $ 21,361.08 04/23/18 2035 $ 21,361.08 168
02/12/18 $ 35,790.70 04/23/18 2036 $ 35,790.70 70
04/20/18 $ 32,818.93 05/22/18 2173 $ 32,818.93 32
07/31/18 $ 37,659.71 08/21/18 2202 $ 37,659.71 21
08/28/18 $ 320.00 02/06/19 2238 $ 320.00 162
10/31/18 $ 33,336.71 02/06/19 2238 $ 33,336.71 98
01/18/19 $ 45,547.77 05/22/19 2287 $ 45,547.77 124
04/26/19 $ 33,796.99 05/22/19 2287 $ 33,796.99 26
07/30/19 $ 27,836.61 10/28/19 2336 $ 27,836.61 90
10/11/19 $ 19,703.82 11/30/20 2450 $ 19,703.82 416
Total Amount: $ 625,000.00 $ 625,000.00

As illustrated in Table C, the final electronic payment the Foundation received from HHS occurred on 10/11/19
in the amount of $19,703.82. The Foundation did not issue a check to the District for the $19,703.82 until
11/30/20 [416 days later]. The SIG calculated the average amount of days between the date the Foundation
received funds from HHS and the date the Foundation issued a check to the District was 92 days.
The District did not make a determination and assessment of the Foundation as a component unit with its
external auditors, which is defined in Statement No. 14 7 of the Governmental Accounting Standards Board
(GASB) as:

7
Also see GASB Statement No. 39, which is an amendment of GASB Statement No. 14 (issued 5/02)
17
 “Component units are legally separate organizations for which the elected officials of the
primary government are financially accountable. In addition, component units can be other
organizations for which the nature and significance of their relationship with a primary
government are such that exclusion would cause the reporting entity’s financial statements to
be misleading or incomplete.”
Foundation’s failure to conduct annual audits
The SIG determined the Foundation did not conduct an annual audit nor did it provide an annual audit to the
District superintendent as required by the Foundation’s by-laws.
Because the federal funds were deposited into a Foundation account, the grant funds were not included as part
of the District’s single audit, which contains a schedule of expenditures of federal awards the District receives
each year. The HHS relied on the District’s external audits, and, therefore, did not conduct its own audits.
Foundation receipt of SC CARES funding
On 11/1/20, the Foundation applied for SC CARES funding and included the District’s federal grant money for
2019. The Foundation reported a $168,776 loss in gross receipts, which included $81,337.42 of federal grant
dollars awarded to the District, not the Foundation. Consequently, the Foundation received the maximum
award of $50,000 made by the state for SC CARES funding to nonprofit organizations. On 12/31/21, the
Foundation issued a check in the amount of $50,000 to the Central Carolina Community Foundation.
The SIG determined the Foundation overstated its gross receipts by at least $81,337.42 in its application for SC
CARES funding.
Teacher grant donations diverted to a Foundation bank account
According to a news release posted on the District’s website on 10/26/17, the Sparkleberry Country Fair
presented a $25,000 check to “Richland Two Superintendent Dr. Baron Davis” for teacher grants. The news
release stated the grant funds would be used for 40 teacher projects that included the purchase of ukuleles at
Rice Creek Elementary, Sphero Robots at Summit Parkway Middle, World War I memorial supplies at Dent
Middle School, and Markerspace labs for several schools.
The SIG determined the $25,000 check from the Sparkleberry Country Fair was not deposited into a District
bank account; rather, it was deposited into a Foundation bank account on 10/31/17.
Foundation use of $9,500 funds in support of the 2018 Bond Referendum
The SIG identified on the Foundation’s 2018 IRS Form 990 an expenditure of $9,500 for a public opinion
survey to determine the level of public support for a proposed bond referendum. The SIG obtained the survey
questionnaire and answers as well as the survey summary notes from the vendor.
The SIG assessed that the District’s use of Foundation funds potentially did not comply with IRS requirements
regarding nonprofit corporations.
Other observations
The SIG noted the District did not have an internal auditor position, which is a vital function as an internal
watchdog over fiscal and program matters.

18
 E. Findings and Recommendations – Fiscal Affairs
Finding #FA-1: The District failed to identify it sought and received a written opinion from the Division of
Procurement Services that its procurement code was substantially similar to the Consolidated Procurement
Code per SC Code of Laws §11-35-5340. The SIG confirmed this with the Division of Procurement Services.
Recommendation #FA-1: The SIG recommends the District adopt the 2021 Model School District
Procurement Code or submit the District’s procurement code to the Division of Procurement Services
for a written opinion as required by SC Code of Laws, §11-35-5340.
Finding #FA-2: The District did not comply with the SC Code of Regulations 19–445.2165 (A) and (B) when
it executed a contract with Service Solutions after receiving the promise of gifts, such as student scholarships
and donations.
Recommendation #FA-2: The District should ensure that procurement officers review responses to all
requests for proposals to ensure compliance with the SC Code of Regulations 19–445.2165 (A) and (B)
and not accept gifts, such as student scholarships and donations, either directly or indirectly from current
or potential contractors in order to avoid the appearance of influence in a contract award.
Finding #FA-3: The District did not identify a Procurement Card Policy.
Recommendation #FA-3a: The SIG recommends the District implement a Procurement Card policy
that is substantially similar to the “South Carolina Purchasing Card Policy and Procedures” published on
the Division of Procurement Services website.
Recommendation #FA-3b: The SIG recommends the District audit the P-Card transactions identified
in Table B and determine the purpose of items 1, 3, 4, and 5 and the expenditure of funds in support of
District program, and report the results of the audit to the SIG by 3/31/23.
Finding #FA-4: The District maintained a checkbook in the HR department to pay for SLED background
checks of employee candidates. The use of the checkbook violated District policies DGA and DK by using the
signatures of HR staff on these checks instead of the District superintendent and chief financial officer. The
SIG’s review of the accounting records for this account did not find evidence of misuse of funds; however, the
use of the checkbook outside of the Finance department’s authority created an internal control deficiency and
elevated the risk for fraud. The District took immediate action, removed the checkbook from the HR
department, and closed the account when the matter was brought to District leadership’s attention. This matter
has been addressed. No further action is required.
Finding #FA-5: The District’s relationship with the Foundation was not governed by an operating agreement or
Memorandum of Understanding (MOU) that governed the Foundation’s use of District resources and personnel.
As a result, the District and the Foundation lacked sufficient internal controls and processes that resulted in the
Foundation depositing monies and federal grant funds intended for the District into a Foundation bank account.
Recommendation #FA-5: The District should develop an operating agreement or MOU with the
Foundation that sets forth the Foundation’s roles and responsibilities in the use of District resources and
personnel.
Finding #FA-6: Federal grant funds in the amount of $625,000 that were awarded to the District were diverted
into a Foundation account, which excluded the $625,000 from the District’s annual audits. Consequently, HHS
misdirected the reimbursement of District expenditures to the Foundation’s bank account instead of the
District’s bank account. The Foundation delayed repayment of the federal grant funds to the District because no
mechanism had been established between the District and the Foundation to facilitate the transfer of funds. In
19
addition, the SIG identified at least 35 checks payable to the District totaling $138,575.44 were deposited into a
Foundation bank account.
Recommendation #FA-6: The District should adopt internal controls and processes with the
Foundation to ensure that funds intended for the District are deposited into a District account.
Finding #FA-7: The District did not make a determination and assessment of the Foundation as a component
unit for its external auditors as defined in Statement No. 14 of the Governmental Accounting Standards Board
(GASB).
Recommendation #FA-7: The SIG recommends the District conduct an assessment of the Foundation
and seek a professional opinion from its external auditors to determine if the Foundation should be
disclosed as a component unit of the District.
Finding #FA-8: The SIG determined the Foundation utilized commingled funds when it reported a $168,776
loss in gross receipts that included $81,337.42 of federal grant funds awarded to the District, not the
Foundation. The $81,337.42 in federal grant funds supported the Foundation’s application for and subsequent
receipt of $50,000 in SC CARES Act funds. The Foundation issued a check for $50,000 to the Central Carolina
Community Foundation on 12/31/22 that did not go to the benefit of the District. The SIG further determined
the Foundation utilized $9,500 in commingled District funds to conduct a public opinion survey regarding a
2018 bond referendum.
Recommendation #FA-8: The SIG will refer the receipt of SC CARES Act funding by the Foundation
to the South Carolina Office of the Attorney General, which has jurisdiction over nonprofit corporations
for investigation of the Foundation’s tax-exempt status and the receipt of the SC CARES Act funds.
Finding #FA-9: The District did not have an internal auditor position or function to conduct fiscal and program
assessments for District leadership and the Board of Trustees.
Recommendation #FA-9: The SIG recommends implementing an internal audit program.

V. Human Capital
A. District Staffing
For the 2021-22 school year, a District staff roster identified 4,794 District employees. As depicted in the data
the District provided to CERRA 8 in the November 2021 report, the District employed 2,081 teachers and 2,713
administrative and support staff. The CERRA report also depicted there were 273 new hires, but 329 teacher
resignations for a 15.4% turnover rate for the District in 2021-22. The SIG determined that 86 vacant teaching
positions existed in the District as of 8/31/22.

8
South Carolina Annual Educator Supply & Demand Report, Center for Educator Recruitment, Retention, & Advancement (CERRA),
Rock Hill SC, November 2021.
20
 Certified Certified Teacher Certified
Teacher Teacher Positions Retention Teacher Turnover
School Year Positions New Hires Retained Rate Resignations Rate
2018 - 2019 2073.5 329 1764.5 85.0% 309 15.0%
2019 - 2020 2089.5 357 1761.5 84.0% 328 15.7%
2020 - 2021 2138.5 270 1944.5 91.0% 194 9.0%
2021 - 2022 2136.5 273 1807.5 84.6% 329 15.4%

The District provided a schedule of substitute teachers and international teachers hired over the past four years
to supplement the teacher vacancies.

Active International Average

Substitute Retention Teachers Cost per
School Year Teachers Rate School Year Hired Total Cost Teacher
2018 - 2019 404 105.0% 2018 - 2019 * $369,000 *
2019 - 2020 461 114.0% 2019 - 2020 28 $634,500 $22,661
2020 - 2021 390 84.5% 2020 - 2021 11 $648,250 $58,932
2021 - 2022 219 56.0% 2021 - 2022 27 $817,900 $30,293
* The District did not provide the number of international teachers hired for the 2018 – 2019 school year.

Provided below is summary breakdown of the teaching and support staff for the 2017-18 through 2020-21
school years obtained from the Annual Comprehensive Financial Report for FY 2020-21 (pages 136 and 137):

Full-Time Equivalent School District Employees by Type

2018 2019 2020 2021
Instruction
Teaching Faculty 2,059 2,019 2,114 2,119
Other 565 626 614 619
Total Instruction 2,624 2,645 2,728 2,738

Support Services
Principals 37 36 36 36
Assistant Principals 85 84 80 80
Other Administration & Support 995 997 965 964
Total Support Services 1,117 1,117 1,081 1,080
Total 3,741 3,762 3,809 3,818

Student Enrollment 28,056 28,359 28,549 27,873

Source: District Records
Note: Full-time instructional employees of the District are employed for all 180 scheduled school days, at seven
hours per day or 1,260 per year. Total work hours by instructional employees are divided by 1,260 to obtain full-
time employment. Full-time equivalent employment for all other positions is determined based on 1,820 hours per
year (52 weeks times five days times seven hours).

International teachers
The District made numerous efforts to recruit and retain teachers. One such effort was the International Teacher
Initiative. Through this program, the District hired international teachers in a variety of content areas, such as

21
math, science, special education, English as a second language, and foreign language instruction. The District
advised it has 38 languages, other than English, represented among its student population.
Authority for the program derived from the Mutual Educational and Cultural Exchange Act of 1961, also
known as the Fulbright-Hays Act. The purpose of the Act was to increase mutual understanding between the
people of the United States and the people of other countries through educational and cultural exchanges. The
SCDE allows school districts to host up to ten percent (10%) of their certified staff as international teachers.
For the 2022–23 school year, the District hired 60 international teachers at a cost of $498,500 in fees. The
District reported it currently has 116 international teachers in District classrooms for the 2022-23 school year.
The District stated that most of the international teachers were hired at the entry level on the teacher salary
schedule. The District saved approximately $18,240 per teacher in benefit costs since the District did not incur
retirement costs, FICA, or health insurance costs.
Over the past four school years, the District paid $2,469,650 in fees to third party recruitment/placement firms
to employ the international teachers who are limited to five years of employment with the District, rather than
utilizing bonuses to retain and recruit teachers.
Retention and recruitment bonuses
The District placed emphasis on retaining current employees with retention bonuses versus signing bonuses for
new hires. In 2020, all full-time permanent employees received a one-time bonus of $1,000. This was repeated
in 2021 and in 2022, where all full-time permanent employees received a one-time bonus of $1,580 and all part-
time permanent employees received a one-time bonus of $789.
The retention percentages of certified teachers in the District for the last five school years were:
• 2017-18 = 86.6%
• 2018-19 = 85.0%
• 2019-20 = 84.0%
• 2020-21 = 91.0%
• 2021-22 = 84.6%
The District has established a 95% retention rate goal for all staff for the 2022-23 school year.
Other Recruitment Efforts
The District recruited teachers through job fairs, the District’s online Handshake portal, travel to colleges and
universities, billboards, Twitter, Facebook, Indeed.com, CERRA’s website, and the Premier 100 initiative. The
HR senior chief stated the candidate pools from job fairs significantly decreased over the last five years
averaging a change from 200 to 30 candidates as the labor market changed due to the effects of COVID, which
caused more teachers to retire.
In 2018, the District and Columbia College entered into a partnership to certify teacher’s aides, especially for
SPED positions. The initiative, the Alternative Pathways to Educator Certification (APEC) program, has
produced 68 teachers who graduated from the program with teacher certifications and Master’s in Education
degrees. Thirty-two of these teachers were employed by the District, including 19 early childhood educators,
nine SPED teachers, one middle-level math teacher, and one secondary-level English teacher. Eight of the
APEC fellows were employed in critical needs schools and thirteen were employed in schools with a poverty
index of 60 or higher. Nine teaching assistants were currently enrolled in the program.

22
The SIG assessed that the District’s partnership with Columbia College was an example of a best practice to
address a challenging recruiting environment.
Exit interviews
The SIG analyzed 1,252 exit interviews of certified and classified staff for the period of 1/1/19 through 6/30/22.
This analysis determined that retirement was the predominant reason for the 343 teachers who separated from
the District. Other notable factors for teacher separations included work conditions, culture, and quality of
supervision. In addition, separations for teachers with three to ten years of experience was significant. Table D
below reflects the reasons and experience levels of teachers who separated from the District since 1/1/19.

Table D
Key Reasons for
<1 to 2 yrs 3 to 10 yrs 11 to 20+ yrs % of
Certified Staff Leaving Total
combined combined combined Total
the District
Retirement 4 21 94 119 35%
Culture 20 43 16 79 23%
Work Conditions 30 56 13 99 29%
Quality of Supervision 12 28 6 46 13%
Total 66 148 129 343 100%

B. Premier 100 Initiative

The purpose of the Premier 100 initiative, begun in 2019, was to recruit and retain 100 minority male teachers
by 2024 as role models for minority students. The initiative provided professional development training for on-
board staff, who met the criteria defined by race, national origin, and gender, to retain minority, male teachers.
The professional development training included dinners, speakers, and field trips, including a 6/4/22 trip to the
Penn Center on St. Helena Island, South Carolina.
Since 2019, the District has recruited and hired 80 males of color through the Premier 100 initiative. The
Premier 100 program is consistent with programs such as “Call Me Mister” and other programs across the state
and nation. After the District announced the Premier 100 program in 2019, the Charleston County School
District announced a partnership with the University of South Carolina titled, “Men of CHS Teach” program.
A senior District official stated Premier 100 was a District initiative administered by District staff and expenses
for meals were paid from the District’s general fund. The District utilized federal Title II funds in the amount
of $7,123.39 for professional development that included the purchase of books, event registration, and field
study.
In November 2021, the Foundation issued checks in the amount of $200 each to at least 20 teachers in Cohort 1
and checks in the amount of $250 each to at least 29 teachers in Cohort 2 in support of Premier 100. The
Foundation issued the checks to the teachers based on information supplied by the District. The SIG assessed
that the Foundation acted as the District’s agent and issued the bonus checks or stipends on behalf of the
District.
The SIG recognized the laudable goal of recruiting and retaining minority male teachers to diversify its teaching
ranks, reflect the demographics of the community it served, and provide role models for minority male students.
A state official responsible for addressing equal employment opportunity advised that it was appropriate to
concentrate on recruiting minority, male candidates during the recruitment process, but providing bonuses and

23
professional development to candidates based on race, national origin, and gender was potentially inconsistent
with federal and state law.
As a result, the District advised the SIG that stipends would no longer be given to Premier 100 participants and
information regarding the professional development opportunities in Premier 100 would be shared with all
District employees through the monthly Professional Development newsletter.

C. Human Resources Processes

The HR department, comprised of 22 staff was led by the HR senior chief, an HR executive director, and an
administrative assistant. The remaining staff included the benefits manager and team, the director of teacher
quality, HR coordinators, and HR specialists. The District recently hired a director of HR employment services
and a talent acquisition manager.

District officials at all levels stated their biggest challenge is filling vacant positions and the lengthy hiring
process of candidates in an ultra-competitive hiring environment. These concerns focused on the performance
of the District’s HR department and the perceived lack of urgency in filling vacant positions.

These same officials attributed HR’s slow processing times to an inadequate staffing level that was partially
attributed to high turnover in HR staff. The SIG determined through interviews and a review of HR processes
that the HR department requires an additional four HR specialists to meet the hiring process needs.

In January 2022, a former senior member of the HR department provided an analysis of HR department
employee grievances, operational shortcomings, and administrative deficiencies to the superintendent. As a
result, the superintendent directed that a climate survey of the HR department be conducted by an outside
consultant.

The climate survey report, dated 3/4/22, confirmed to the superintendent that limited staff resources, the lack of
standardized processes, high staff turnover, a difficult work environment, and limited feedback and recognition
on work performance contributed to the operational shortcomings and administrative deficiencies.

The operational shortcomings and administrative deficiencies reported to the superintendent and identified by
the SIG included the lack of standard operating procedures and a pay policy manual, an audit of teacher pay
scale step increases based on certification changes, and late paychecks to newly hired employees, as detailed
below.
Desk Manual for Standard Operating Procedures
The SIG determined the HR department lacked a desk manual of standard operating procedures for the daily
processes by position within the HR department.
Pay Policy Manual
The HR department lacked a pay policy manual for its payroll procedures. Instead, the HR department relied on
a collection of memos, emails, and documents (84 pages) dating back to 1992. The SIG’s examination of this
anthology of payroll procedures found inconsistencies in salary computation based on position and/or
experience. (See Appendix H)

24
Audit of teacher payroll accuracy
In late 2021, the HR department initiated an audit for accuracy in teacher payroll that focused on teacher
certification, experience, and the corresponding step on the teacher pay scale. The audit identified the pay of 66
onboard teachers dating back to 2012 was collectively underpaid $459,381. The underpayments ranged from
$779 to $45,230.
The audit resulted in 31 of the 66 employees retroactively paid $276,979 on 2/14/22. The HR and Finance
departments completed the audit and made retroactive payments to 35 teachers on 10/11/22 that totaled an
additional $182,402.
Late employee paychecks
The first payroll check for the 2022-23 school year was 8/15/22. One-hundred ninety (190) new employees and
on-board employees in new District positions did not receive a paycheck on 8/15/22. As a result, the Finance
department issued additional payroll checks on 8/15/22 for nine employees, 8/17/22 for three employees, and
8/25/22 for 178 employees. The late payroll payments were caused by the failure of the HR department to
make entries by the 8/5/22 payroll deadline, which had been published in advance by the Finance department.
A second payroll run was not uncommon at the beginning of the school year. The SIG determined higher than
normal teacher retirements and departures coupled with the processing of additional instructional staff for the
Summer Opportunity for Academic Readiness (SOAR) program contributed to a backlog in HR processing that
resulted in the untimely processing of HR payroll data.

Non-uniform timekeeping processes

Time and attendance records for substitute teachers, after-school employees, summer employees, and bus
drivers were maintained on the TimeClock Plus system. No other employees were required to record their time
worked in this way. Instead, each of the school principals maintained separate sign-in/out registers for their
exempt and non-exempt employees. Principals stated that assistant principals and assistant administrators
walked the halls to determine the need for substitute teachers when a teacher had not provided advance notice of
absence.
Officials also stated that there was no district-wide means to track the accumulation or use of compensatory
time by non-exempt employees, nor did it ensure the remaining unused balance was paid out at the end of the
fiscal year as required by Policy GDBC – “Support Staff Supplementary Pay/Overtime.”
The SIG determined that the District lacked uniform internal controls relating to reconciling payroll with the
accumulation of compensatory time.
Performance evaluations
The District complied with SCDE requirements for performance evaluations of its certified staff and
administrators as required by its policies GCO and GCOA as outlined below.

• Policy GCO “Evaluation of Administrative Staff,” required annual evaluations of school

administrators. The District used SCDE’s “Program for Assisting, Developing, and Evaluating
Principal Performance” (PADEPP), and its associated Performance Standards and Criteria for
Principal Evaluation as adopted by the State Board of Education for conducting evaluations of
principals.

25
 • Policy GCOA “Evaluation of Instructional Staff,” provided for evaluations of instructional staff
on a periodic basis 9. The District used the ADEPT System to evaluate all certified teachers in
accordance with SCDE ADEPT guidelines.
• Policy GDO “Evaluation of Support Staff,” required that all support staff of the District must be
formally evaluated their first year and at least once every two years thereafter.
However, exit interviews conducted of 1,252 staff between 1/1/19 and 6/30/22 demonstrated that 200
individuals (16%) stated they did not receive annual performance evaluations. Performance evaluations may be
used to provide feedback, coaching, and documentation of poor performance, as well as positive feedback for
good performance. Proper documentation of performance is essential when seeking termination of a poor
performer or justifying bonuses for excellent performance.
No staff disciplinary matrix
The District did not have a staff disciplinary table or matrix similar to its student disciplinary table. The HR
department, however, maintained a spreadsheet of employee misconduct matters that included historical
information of prior disciplinary recommendations. HR leadership referred to the spreadsheet to ensure
consistency when recommending disciplinary action in employee misconduct matters. HR leadership described
the disciplinary decision-making process as “we huddle” to determine how to address misconduct issues.
The SIG determined the HR department had not maintained the spreadsheet for accuracy and that it was last
updated two years ago. Since the initiation of this investigation, the District has started updating the
spreadsheet.
D. Investigative Process for Employee Misconduct Matters

No documented investigative process for employee misconduct matters

The SIG did not identify any documented process that prescribed or authorized the manner or means by which a
misconduct investigation is conducted, documented, and formally reviewed. A documented investigative
process promotes a transparent process for the employee and enhances trust in its fairness and consistency that
due process safeguards are established for the employee.
The SIG determined that employee misconduct investigations were supervised or conducted by three HR
department staff members. Classified staff misconduct investigations were supervised or conducted by an HR
specialist. The HR executive director supervised or conducted misconduct investigations of teachers, assistant
administrators, and assistant principals. Finally, the HR senior chief supervised or conducted misconduct
investigations of principals and senior District officials.

District employees that investigated employee misconduct, whether in the HR department or at its direction, had
limited experience or training in conducting these investigations. The SIG determined HR staff had little
familiarity with the investigative process, including an understanding of the importance of collecting and
documenting the facts, obtaining witness statements, gathering sufficient evidence necessary to draw a logical
conclusion, and ensuring all legal requirements and protections for employees were addressed. The HR
department served as both the investigative and the case review authority for employee misconduct.

The SIG assessed that the combination of untrained and inexperienced investigators, the lack of documented
investigative procedures, and combining the investigative and case review processes within the HR department
created, at a minimum, the appearance of investigative bias.

9
Teachers are rated by the SCDE-mandated “Assisting, Developing, and Evaluating Professional Teaching” (ADEPT) system.
26
The SIG determined separate chains-of-command should conduct the investigative process and the case review
process that includes a legal review.

Failure to disclose conflicting witness statements

A recent employee misconduct investigation supports the SIG’s recommendation of separating the investigative
process from the case and legal review processes.

During the SIG’s investigation, the SIG learned of the removal and demotion of a school administrator
following allegations of misconduct. The misconduct investigation included interviews of the complainants and
other witnesses, as well as receiving oral briefings from staff assigned to assist the school. The SIG determined
from a review of the investigative file the witness interviews were neither documented nor recorded.

The school administrator appealed the disciplinary action and requested the investigative documents that
formed the basis for the disciplinary action. In response, the District provided documents to the school
administrator, but a voluntary witness statement that was exculpatory in nature was not included in the
documents provided to the school administrator. The school administrator acquired the exculpatory statement
outside of the District’s production of materials and the administrator provided the exculpatory statement to the
Board as part of the school administrator’s appeal. Prior to the Board hearing the appeal, the District reached a
settlement with the school administrator.

The SIG’s review and analysis of the District’s investigative file determined the following:

• The investigative file was poorly documented and omitted some witness statements taken by the
investigative team.
• The investigative file contained handwritten witness statements and emails that conflicted with
each other and were exculpatory in nature.
• The investigative file failed to document the materials produced to the school administrator or
counsel.

Establishing standard operating procedures for conducting investigations of employee misconduct should
include procedures for documenting witness statements, gathering evidence, and documenting a case review of
the investigative results, along with a legal review that would promote a fair and thorough investigative process
and consistency in the determination of any disciplinary action.

E. Findings and Recommendations – Human Capital

Finding #HC-1: The District spent nearly $2.5 million over the last four years in payment to vendors to
acquire international teachers who were limited to five years of employment with the District.
Recommendation #HC-1: The SIG recommends the District consider utilizing bonuses to retain and
recruit teachers to work in the District.
Finding #HC-2: The District established the Premier 100 initiative to recruit and retain 100 men of color by
2024 and paid for professional development training and related expenses, including dinners, speakers, and field
trips, as well as stipends to these teachers. The District terminated the distribution of stipends to Premier 100
participants and opened the professional development opportunities provided by Premier 100 to all District
employees. No further action is required.

27
Finding #HC-3: The HR department lacked standard operating procedures for daily HR processes and a
comprehensive payroll policy manual that resulted in inconsistences in salary computations based on position
and/or experience, which adversely affected various HR functions and payroll functions in the Finance
department.
Recommendation #HC-3a: The SIG recommends the District HR department establish standard
operating procedures for daily processes and a payroll policy manual to ensure consistency in salary
computations.
Recommendation #HC-3b: The SIG recommends the District engage an external organizational
management group to conduct a comprehensive study of the HR department’s processes to identify
inefficiencies and strategies for improvement.
Finding #HC-4: The District conducted an audit of onboard teacher payroll for the period of 2012 – 2022 that
identified underpayments totaling $459,381 related to certification changes and step increases. Retroactive
payments were made to the onboard employees between February 2022 and October 2022.
Recommendation #HC-4: The District should ensure teacher payroll audits are conducted annually to
ensure accuracy in teacher certifications, experience and step increases.

Finding #HC-5: The HR department was delinquent in processing payroll data of 190 employees resulting in
late payments for paychecks scheduled for 8/15/22, in part due to inadequate staffing.

Recommendation #HC-5a: The SIG recommends cross-training HR personnel to ensure timely data
processing of new hires during the summer hiring season.

Recommendation #HC-5b: The SIG recommends an increase of four HR specialist positions in HR

department.

Finding #HC-6: The HR department is responsible for investigating employee misconduct and conducting a
case review, which creates a risk of investigative bias in determining disciplinary action, if any. The SIG
determined the officials who conducted the misconduct investigations had limited investigative training and
experience. A recent employee misconduct investigation was poorly documented and contained exculpatory
information and conflicting witness statements. The District failed to provide the exculpatory witness
statements to the employee in support of the employee’s appeal of the disciplinary finding.

Recommendation #HC-6: The SIG recommends the District separate the investigative process from
the case review process that includes a legal review of the investigative results to mitigate the risk and
appearance of investigative bias in determining disciplinary action, if any.

Finding #HC-7: The District did not have a unified district-wide time and attendance system to track
compensatory time.

Recommendation #HC-7: The SIG recommends the District establish a unified district-wide time and
attendance system, the purposes of which would include tracking compensatory time and compensatory
time off.

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 VI. Board of Trustees
The SIG examined the effectiveness and efficiency of the Board with particular focus on intra-Board conduct
and relations, the Board’s interaction with the District, and the Board’s interaction with the public. With respect
to its interaction with the District, the SIG examined the effect of the Board’s conduct on the District operations,
fiscal affairs, and human capital.

The SIG conducted an analysis of all Board meeting agendas for the 2018-19 through 2021-22 school years, and
referred to the archived recordings of the Board meetings as needed. The SIG determined the Board addressed
academic matters in only 14.2% (39) of the 274 Board items over the last four school years. For the most recent
two school years (2020-21 and 2021-22), the Board scheduled only five academic items, or 6%, with none
during the 2020-21 school year.
2018-19* 2019-20 2020-21 2021-22
Board Agenda Items Total
School Year School Year School Year School Year
Academic 1 33 0 5 39
Non-Academic 114 45 30 46 235
Total Agenda Items 115 78 30 51 274
Board Chair McKie Manning Shadd/Manning Holmes
* The Board conducted a review of all District policies during the 2018-19 school year.

A. Board Decorum and Dysfunction

The SIG observed dysfunctional or non-existent communication and a lack of trust among Board members.
Each Board member contributed to its dysfunction and ineffectiveness through petty disagreements and
personal attacks of other Board members. During the course of this investigation, the SIG observed an increase
in communication failures between the Board and the superintendent that affected the morale and productivity
of District staff.
The Board demonstrated inconsistency in the application of policies and procedures established for the District
and Board member behavior and decorum. The Board members are public figures who are looked upon to
provide an example to District students and staff on decorum and collegiality. (See Board Policy BC) As one
Board member expressed, “the Board members are ambassadors for the District.”
The SIG identified acrimonious comments between fellow Board members and toward public speakers at Board
meetings, disruptive behavior, such as the 9/14/21 walkout by three Board members that halted Board work for
lack of a quorum, and executive sessions that devolved into vulgar name-calling where executive sessions were
terminated without accomplishing its work.
The Board failed to follow Policy BC “Board Member Conduct,” which, inter alia, provided the following:

• Become familiar with district policies, rules and regulations, state and federal school laws, and
regulations of the South Carolina Department of Education.
• Work harmoniously with other board members without trying to either dominate the board or
neglect one’s share of the work.
• Refuse to participate in irregular meetings, such as secret meetings, which are not official and
which not all members have the opportunity to attend.
• Maintain the confidentiality of all matters discussed in executive session.
• Understand that the basic function of a school board is policymaking, not administration, and
accept the responsibility of learning to discriminate intelligently between these two functions.
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The Board is the authority for establishing District-wide policies for students, staff and itself. However, it failed
as a body to abide by Policy GBEB “Staff Conduct,” which mirrors Policy BC and states:
• The Board reaffirms one of the oldest beliefs in education, which is that one of the best
methods of instruction is that of setting a good example.
• The Board expects the district’s employees to strive to set the kind of example for
students that will serve them well in their own conduct and behavior and subsequently
contribute to an appropriate school atmosphere.
• To that end, all employees should recognize that they are continuously being observed by
students, other employees, parents/legal guardians, and community members and that
their actions and demeanor may impair their effectiveness as an employee.
Consequently, employees will ensure that their dress, conduct, written and spoken
communication, attitude, and interactions with others demonstrate an appropriate level
of professionalism at all times.

1. Consultant Assessment of Board members

In 2022, the Board contracted a well-respected executive consultant, coach, and facilitator to address intra-
Board relationships to improve the efficiency and effectiveness of Board governance. The consultant described
the Board as transactional, rather than strategic. The consultant stated the Board was in high conflict, with
noticeable factions and conflict entrepreneurs who fanned the flames and used parliamentary procedures, legal
threats, and disrespectful language to humiliate other Board members. Together, these behaviors fostered a
hostile environment, which created reputational, operational, and legal risk. The consultant stated the Board
was the most dysfunctional he/she had ever encountered. (See Appendix I)
During the 2021-22 school year, under the leadership of Dr. Holmes, Board meetings frequently deteriorated
into shouting matches among the members. A nationally recognized expert on parliamentary procedures
consulted by the SIG opined that a “comfortable chair” would have accommodated minority viewpoints to
encourage debate, rather than purport to use Robert’s Rules of Order to stifle dissent. As a result, members with
a minority viewpoint expressed frustration with placing items on the agenda for discussion. A lack of trust
among Board members manifested itself, among other things, in the Board’s inability to use committees to
support its work. (See Board Policy BDG “Board Committees”)

After examining numerous videos of Board meetings and conducting interviews of Board members, current and
former District staff, and members of the public, the SIG concurred with the consultant’s observations that
Board member conduct fostered a hostile environment, which created reputational and operational risk.

B. Board Oversight and Roles

Board members were not aligned on the role of the Board. The majority of Board members suggested, and one
member expressed, that the role of the Board was to “support the superintendent.” Board members generally
acknowledged they worked for and represented the citizens; however, there was a distinct difference in
perspective between a group of four members (“Group of Four”) consisting of Board members: Holmes,
McKie, Caution-Parker, and Manning; and a group of three members (“Group of Three”) consisting of Board
members: Agostini, Scott, and McFadden. The Group of Four consistently emphasized that the Board set goals
and “stayed out of the weeds.” Significantly, however, the Board had little, if any, role in writing the District’s
strategic plan, which contained the goals for the District. (See Appendix J)

Most Board members did not seem to understand their oversight role and responsibility. For example, even
after news accounts of P-Card problems in Richland County School District One, Dr. Holmes stated she saw no
30
need to inquire about what steps the superintendent had taken to ensure no P-Card problems had occurred in the
District because the superintendent had not initiated [SIG emphasis] a report about any procurement card
irregularities.

The SIG noted the District did not have an internal auditor to conduct an independent review of District
finances and programs; therefore, it was incumbent on the Board to ensure the District’s internal controls
functioned properly.

When questioned about financial issues, such as the late payroll payment of teachers in August 2022, incorrect
payment of teachers dating back to 2012 that resulted in back-pay disbursements totaling $459,381, issues
concerning the Foundation, and procurement matters, the Board members expressed they were unaware of these
issues, an indication the Board failed to provide the necessary oversight and communication with the
superintendent on these important issues.

C. Surreptitious Recording of Board Executive Session – 4/28/22

On 4/28/22, the Board voted to go into executive session, the proceedings of which were confidential under
Board Policy BC “Board Member Conduct.” During the executive session, Board vice-chair Manning
surreptitiously recorded the proceeding that was later aired by a local television station. (See Appendix L)

During the executive session, Mrs. McFadden objected to a report given by the superintendent on school
security and safety because she believed subject should be debated in an open Board meeting. Dr. Holmes
laughed at Mrs. McFadden and called her “little girl,” “Boo,” “baby,” and “honey.” Following an escalation in
the verbal exchange, Mrs. McFadden stood over Dr. Holmes with a hand in Dr. Holmes’ face in a threatening
manner. The verbal exchange included:
Dr. Holmes (interrupts): Go ahead. Finish your statement, honey. Do what you gotta do.
Mrs. McFadden: Shut the fuck up
Multiple people: (audible gasp)
Dr. Caution-Parker: Oh, come on.
Dr. Holmes: Little girl, little girl, little girl (in a mocking tone).
Mrs. McFadden: Cause I’m fed up with you.
Dr. Holmes: Oh. It’s okay (keeps repeating this as Mrs. McFadden tries to speak).
Mrs. McFadden: You want to call me a little girl? I found out what “little girl” means.
Dr. Holmes: Oh. It’s okay. Are you upset? (in a condescending tone).
Mrs. McFadden: I found out what it means. If you think that I was a little girl before,
you…(unintelligible).
Dr. Holmes: It’s okay. Are you upset?
Mrs. McFadden: No, I’m not upset.
Dr. Holmes: Are you upset, Lashonda?
Mrs. McFadden: No, I’m not. I’m just letting you know right now that I will fuck you up
and the dick you rode in on.

The terms “little girl” and “Boo” are generally understood to be demeaning, especially when referring to a black
female because of its association with the slave status of black females in the 19th century.

The SIG assessed the terms, along with Dr. Holmes’ use of “honey” and “baby” were provocative, intended to
demonstrate an appearance of authority over Mrs. McFadden. Dr. Holmes’ conduct was inconsistent with the
requirement in Board Policy BC to “work harmoniously with other board members….”

31
The SIG determined Mrs. McFadden violated Board Policy BC regarding her threats toward Dr. Holmes. 10

Mr. Manning stated to the SIG that the executive session had not started when he started the recording. The
SIG determined the recording began during executive session as Superintendent Davis is heard on the recording
discussing security and safety matters. Mr. Manning acknowledged that he released the recording to third
parties, but denied under oath to releasing the recording to the media. The surreptitious recording of the
executive session by Mr. Manning violated Board Policy BC.

The SIG identified text messages on Dr. Holmes’ cellphone that were sent and received on 5/8/22 that
referenced the 4/28/22 executive session and contained the following:
Mr. Manning: The audio has been given to the media. Edited so it has no business on it.
Dr. Holmes: Who gave it?
Mr. Manning: Me
Dr. Holmes: Oh
Mr. Manning: It is time. [Named person] and them are mounting a campaign against us.
Dr. Holmes: I’m ready.
Mr. Manning: Everything and anything they have or think they have
Mrs. McKie: [emoji] Loved. “The audio has been given to the media. Edited so it has no
business on it.”

The SIG discerned that the referenced text message string was a three-way text between Dr. Holmes, Mrs.
McKie, and Mr. Manning. Discovery provided by the District contained only the Dr. Holmes’ records
regarding the 5/8/22 text and not the corresponding texts of Mr. Manning and Mrs. McKie. The SIG noted that
both Mr. Manning and Mrs. McKie were sent preservation letters on 6/29/22.

The SIG determined that Mr. Manning violated Board Policies BC, BCA, and BEC by recording the executive
session and disclosing it to third parties that resulted its distribution to the media. A prominent First
Amendment attorney opined that surreptitious recording of executive session meetings is neither prohibited by
SC Code of Laws §17-30-10 et seq nor FOIA.

The SIG determined through a review of Dr. Holmes’ text messages that both Dr. Holmes and Mrs. McKie
were informed by Mr. Manning that he released the recording to the media, including Mrs. McKie’s approval of
Mr. Manning’s text. The SIG notes that Dr. Holmes was aware, during her tenure as Board chair, that the
recording was made by Mr. Manning, but took no action to address the violation of Board Policy BC and the
breach of trust among members of the Board.

The SIG assessed that the surreptitious recording itself and its release to the media further eroded trust among
Board members, and thereafter Mrs. McFadden and Dr. Scott attended executive sessions telephonically from a
nearby room. The erosion of trust exacerbated the inefficiency and ineffectiveness of the Board.

D. Board – Superintendent Relationship

Board Policy BC establishes that Board members are to “Give the superintendent full administrative authority
for properly discharging his/her professional duties and hold him/her responsible for acceptable results.” The
SIG identified during the course of this investigation the Group of Three failed to adhere to this policy and
provide the superintendent full administrative authority to run the District.

10
Further information regarding this event may be found through open source reporting.
32
In a 4/28/22 email to Superintendent Davis, members of his staff, and all Board members, Mrs. McFadden
admonished Superintendent Davis to produce information on Board member travel and placed on him the
responsibility of approving the over-spending of Board member accounts. Mrs. McFadden stated:
“This will definitely be a cause for insubordination and direct effect on your evaluation. Yes, as a
matter of fact, I’m going on record questioning your integrity.”
The Board’s general failure to exercise its oversight while recognizing the superintendent’s “full administrative
authority” fractured the lines of communication of a healthy Board – Superintendent relationship. Equally
important was the superintendent’s responsibility of keeping the Board informed on District matters. Both the
Board and the superintendent failed to adhere to Board Policy-BDD “Board Superintendent Relationship.”
Superintendent Davis is charged with overseeing a $300 million budget of taxpayer dollars to deliver public
education to school-age children in the District. As the only direct report of the Board, Superintendent Davis is
in the unenviable position of ensuring the expenditure of taxpayer dollars for Board travel is supportive of
public education and the educational goals of the District.
1. No contact directive issued to Lashonda McFadden
On 12/8/21, Mrs. McFadden visited the District office at the R2i2 building and demanded to see the
superintendent. Mrs. McFadden’s visit was occasioned by an incident involving a student with a firearm at
Richland Northeast High School. Superintendent Davis was unavailable to meet Mrs. McFadden during her
visit but spoke with her by phone. Staff advised the SIG that Mrs. McFadden raised her voice and made
demands directly to the staff for specific action. The staff characterized Mrs. McFadden’s behavior as
inappropriate and adversely affected the work and morale of District staff. This event resulted in Dr. Davis
issuing a “no contact” letter through his personal attorney to Mrs. McFadden, except for Board meetings.
Board Policy-BDD “Board Superintendent Relationship” provided that the Board would “carry on
communications with staff members through the superintendent.” Board policy BHC “Board/Staff
Communication” required that the Board “will make all official communications, policies, and directives of staff
interest and concern to the staff through the superintendent.”
The SIG determined Mrs. McFadden violated Board policies BDD and BHC on 12/8/21. McFadden’s demands
for specific action also violated Board Policy BC “Board Member Conduct,” which provided that “the basic
function of a school board is policymaking, not administration….”

E. Board - District Staff Relationship

Interviews with numerous District officials demonstrated the strong belief that Board behavior had a deleterious
effect on District operations and human capital management. District staff reported that students were aware of
Board behavior during Board meetings and questioned student discipline for the same conduct as that exhibited
by the Board. In addition, staff stated that the District’s reputation has suffered from the Board’s conduct
resulting in job candidates seeking employment elsewhere and experienced teachers leaving the District for
other teaching positions or leaving the profession altogether.
1. 9/14/21 Board Meeting
One such example occurred during the 9/14/21 Board meeting. The agenda for the 9/14/21 Board meeting
included agenda item 8.3 “Superintendent’s Contract.” The minutes of the meeting reflected that Mrs. Agostini
moved, and Dr. Scott seconded, to postpone agenda item 8.3 until the 9/28/21 Board meeting. Chairman
Holmes ruled that the motion was not germane. Thereafter, Dr. Scott and Mrs. Agostini left the meeting,
explaining that they had insufficient time to review the contract. Mr. Manning explained the timeline used in
33
previous years to evaluate the superintendent’s contract. Mr. Manning indicated members received details
regarding the contract on 9/13/21. Mrs. McFadden also expressed concerns about not receiving contract
information in a timely manner and left the meeting.
Policy BEDC “Quorum” established that a minimum of five members is required to conduct board business.
Consequently, the meeting was adjourned for lack of a quorum. The contract was approved at the 9/22/21
meeting by a vote of 5-2. Policy BEDA stated:
The superintendent will distribute printed or electronic notice of each regular meeting of
the board with agenda and supporting materials to board members at least three
business days in advance of the meeting, if possible, to permit them to give items of
business careful consideration.
The SIG determined Dr. Holmes, as the Board chair, violated policy BEDA when information regarding
the superintendent’s contract was not provided to Board members at least three business days in advance
of the meeting and that Board members Agostini, Scott and McFadden violated Board BC for disruptive
behavior to Board operations that resulted in the loss of a Board quorum.
2. 10/25/22 Board Meeting
At the 10/25/22 Board meeting, the District’s senior chief officer for finance (Finance senior chief)
provided an explanation of the District’s need to borrow funds for capital improvements through the
issuance of bonds (Agenda Item 10.1) that could not be paid with funds from the 2018 bond referendum.
The Finance senior chief is a highly regarded expert in economics and financial matters having served as
the South Carolina Board of Economic Advisors chairman and on the faculty of the Moore School of
Business at the University of South Carolina.
During the Board member discussion on this agenda item, Mrs. McFadden demonstrated a line of
questioning toward the Finance senior chief that appeared to question his knowledge and integrity on the
subject matter. At 2:55:21 of the Board meeting, Mrs. McFadden issued an apology to the Finance
senior chief stating, “Dr. Miley, I did not mean to insult you; that’s not what I was trying to say.
Sometimes when I am saying something it doesn’t come out the way that I intended to say…”
Previously, following the 9/27/22 Board meeting, Dr. Scott emailed Superintendent Davis complaining
about two members of the District’s leadership team and requesting an investigation be initiated into
alleged disrespectful behavior, such as hand gestures and facial expressions, whenever Mrs. McFadden
spoke.

F. Board Financial Matters

1. Board member travel budget allocations

For FY 2021-22, the District budget included $63,000 for Board travel. Each Board member was allotted
$7,000 for travel, totaling $49,000 with the remaining $14,000 for expenses incidental to the operation of the
Board, such as travel of the Board liaison. At the close of FY 2021-22, individual Board member travel
expenses totaled $52,800.95, which exceeded their combined budget by $3,800.95, as set forth in Table E
below.

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 Table E
FY 2021-22 FY 2021-22 Final Travel Exceeded
Travel Fund Adjustment
Board Member Travel Travel Expense Travel
Balance To Allotment
Allotment Expenses Balance Allotment
Mrs. Agostini $7,000 $4,975.38 $2,024.62 ($2,024.62) $0
Dr. Caution-Parker $7,000 $3,939.15 $3,060.85 ($1,712.13) $1,347.73
Dr. Holmes $7,000 $11,242.39 ($4,242.39) $1,712.13 $2,529.27
Mr. Manning $7,000 $8,268.55 ($1,268.55) - $1,268.55
Mrs. McFadden $7,000 $6,993.56 $6.44 - $6.44
Mrs. McKie $7,000 $6,993.56 $6.44 - $6.44
Dr. Scott $7,000 $10,388.36 ($3,388.36) $2,024.62 ($1,363.74)
Total $49,000 $52,800.95 ($3,800.95) - ($3,800.95)
Mrs. Agostini agreed to transfer $2,042.62 to Dr. Scott’s budget. Dr. Caution-Parker agreed to transfer $1,713.12 to Dr. Holmes’ budget.
Trustee expenses exceeded the travel allotment. Total expenses exceeded the $49,000 allotment by $3,800.95.

As illustrated in Table E, three Board members exceeded their individual travel allotments by $8,899.30 while
three Board members underspent their allotments by $5,095.35 that resulted in the over expenditure of Board
member travel by $3,800.95. As of 10/31/22, the overall expenditure of District funds for Board travel was
$55,511 for the 2021-22 school year, which was $7,489 under the total travel budget of $63,000. 11 The District
assigned individual account numbers to the Board members beginning with the 2022-23 school year.

2. Board member travel advances

Policy BID “Board Member Compensation and Expenses” includes information related to travel expenses for
conferences. The policy included, “The district will reimburse board members for all reasonable and necessary
expenses incurred in attending any meeting or conference when on official business of the board or the school
district. Such expenses may include the cost of attendance at conferences of school boards associations and
other professional meetings/visitations when these costs are within the budget. Board members will be
reimbursed according to the same expenditure standards as district employees under policy DKC (Expense
Authorization Reimbursement).”

Policy DKC “Expense Authorization/Reimbursement” related to travel and set forth the reimbursable travel
expenses as well as approved rates for Board members and employee expenses incurred during approved
District-related travel.

The SIG determined no District employee [SIG emphasis] received a travel advance during the past four
school years. However, three Board members requested and received travel advances during that same period.

Dr. Holmes received nine travel advances, Dr. Scott received nineteen, and Mrs. McFadden received three. Dr.
Holmes advised she discontinued travel advance requests after Superintendent Davis counseled her on its use.
Board travel advance requests are identified in Table F as follows:

11
Source: District unaudited totals for 2021-22.
35
 Table F

Final Amounts Amount Travel

Travel Date Traveler
Dates of Name of Board Travel Reimbursed Reimbursed/ Funds
Advance Reimbursed/
Travel Traveler Costs to/Owed by Repaid by Owed to
of Funds Repaid
Claimed Traveler Traveler District
1/25-1/30/19 Teresa Holmes ($468.74) $468.74 $0.00
2/20-2/24/19 Teresa Holmes ($299.48) $299.48 $0.00
3/29-4/1/19 Teresa Holmes ($265.42) $265.42 $0.00
8/23-8/26/19 Teresa Holmes ($228.84) $228.84 $0.00
9/25-9/29/19 Teresa Holmes ($348.37) $348.37 $0.00
11/13-11/18/19 Teresa Holmes ($436.81) $436.81 $0.00
12/6/-12/8/19 Teresa Holmes ($223.12) $223.12 $0.00
3/17-3/21/21 Teresa Holmes ($393.48) $393.48 $0.00
8/27-8/29/21 Teresa Holmes ($210.08) $210.08 $0.00
8/24-8/26/18 Monica Scott ($203.12) $203.12 $0.00
9/26-9/30/18 Monica Scott ($340.60) $340.60 $0.00
1/17-1/21/19 Monica Scott ($249.96) $249.96 $0.00
1/26-1/30/19 Monica Scott ($441.33) $441.33 $0.00
2/20-2/24/19 Monica Scott ($305.28) $305.28 $0.00
3/26-4/1/19 Monica Scott ($264.02) $264.02 $0.00
6/16-6/19/19 Monica Scott ($238.52) $238.52 $0.00
6/23-6/27/19 Monica Scott ($311.99) $311.99 $0.00
8/23-8/26/19 Monica Scott ($227.68) $227.68 $0.00
9/25-9/29/19 Monica Scott ($346.86) $346.86 $0.00
11/13-11/18/19 Monica Scott ($435.42) $435.42 $0.00
12/8-12/8/19 Monica Scott ($221.96) $221.96 $0.00
6/19-23/21 Monica Scott ($164.64) $164.64 $0.00
08/28-8/29/21 Monica Scott ($212.32) $212.32 $0.00
11/9-11/14/21 Monica Scott ($471.77) $471.77 $0.00
1/14-16/22 Monica Scott ($199.08) $199.08 $0.00
3/31-4/5/22 Monica Scott ($541.47) $508.51 ($32.96) 5/26/22 $ 32.96 $ -
6/19-6/22/22 Monica Scott ($256.50) $256.50 $0.00
9/29-10/1/22 Monica Scott ($192.88) $0.00 ($192.88) 10/13/22 $ 192.88 $ -
1/21-1/25/21 Lashonda McFadden ($824.90) $0.00 ($824.90) 3/22/22 $ 824.90 $ -
8/27-8/28/22 Lashonda McFadden ($203.75) $203.75 $0.00
9/7-9/10/22 Lashonda McFadden ($283.75) $283.75 ($425.00) 10/19/22 $ 425.00 $ -
*The amount of $425.00 paid by Lashonda McFadden related to amounts charged to the District Purchasing Card for
personal, non-allowable and unauthorized charges (which include room upgrade and pet fee charges)
Total Travel
($9,812.14) $8,761.40 ($1,475.74) $ 1,475.74
Costs

Policy DKC also provided for travel advances in “unique circumstances,” but the policy did not define unique
circumstances, the type of expenses that would be advanced, a timeframe of when the advance would be
provided to the traveler in relation to the travel, when the advance had to be expensed, and when any
outstanding balance had to be repaid.

District employees who requested a travel advance were required to justify the advance on a travel advance
form. One of the categories used for justification was “hardship.” The travel advance form also tracked the

36
advance of funds, applied it against expenses incurred by the traveler, and determined whether the entire travel
advance was expensed or if there was a portion that needed to be repaid to the District.

On occasion, individual Board members did not fully expense the travel advance and had to repay the District.
In one instance, Mrs. McFadden received an advance for travel on 1/21-25/22 but subsequently cancelled her
travel. Superintendent Davis emailed Mrs. McFadden on 2/11/22 and referenced Mrs. McFadden’s
conversation with the Board’s special assistant about the travel advance to attend a symposium and the need to
repay the advance of funds by 2/24/22 since the travel was cancelled. Mrs. McFadden was given 30 days to
repay the travel advance of $824.90. Mrs. McFadden did not repay the advance until 3/22/22, a delay of 26
days.

In another instance, Dr. Scott received a travel advance on 3/31 – 4/5/22 but her out of pocket expenses were
less than the amount of the travel advance. On 5/26/22, Dr. Scott repaid the remaining balance of $32.96, a
delay of 21 days past the 30-day deadline.

In January 2022, when Dr. Scott requested a travel advance, the senior chief financial officer informed Dr. Scott
he could not advance the funds without a reason for approving an exception to the policy. District staff advised
Dr. Scott had not signed the travel form and failed to declare the expense was a financial burden, that the travel
exceeded four days, or some other justifiable reason. Dr. Scott questioned the need to complete the travel
advance form and stated, “elected school Board members are not employees of the school district so the form
should not apply to them when they travel.”

After the travel advance form was recently updated to eliminate advances for expenses that required a receipt
for reimbursement (e.g., taxis, baggage fees, and parking), travel advances were only provided for those known
expenses that did not require a receipt such as per diem and mileage. After the travel advance form was
updated, Dr. Scott became upset because she could not get an advance for expenses she previously received
such as taxis, baggage fees, and parking.

On 10/25/22, the Board revised Policy BID “Board Member Compensation and Expenses” ending the practice
of Board members receiving travel advances and suspended a Board member’s ability to travel until any
outstanding travel balance is paid back to the District.

3. Circumvention of financial internal controls – Lashonda McFadden

District Policy DKC provided that travelers would be reimbursed actual lodging expenses at the higher of the
GSA or applicable convention rate. In addition, travelers were responsible for lodging expenses greater than the
single occupancy rate.

From 9/7/22 through 9/10/22, Mrs. McFadden attended the COSSBA Urban Boards Alliance Symposium in
Atlanta, Georgia where she incurred lodging expenses totaling $2,095.89 that were paid by the District through
direct billing. The conference room rate of $254 per night plus taxes was authorized per policy, but Mrs.
McFadden incurred a $100 per night suite upgrade fee and a $125 pet cleaning fee.

Mrs. McFadden understood the travel policy related to hotel expense reimbursement set forth in Policy DKC
and found in additional material provided to all Board members at the 8/5/22 summer Board retreat. The SIG
determined that Mrs. McFadden’s charges for the upgraded room and cleaning fee were unauthorized personal
expenses that violated Policy DKC and that Mrs. McFadden circumvented District financial internal controls.

Superintendent Davis stated that Mrs. McFadden’s first response to him was to take “it” out of her allotted
Board travel account. Subsequent emails sent by Mrs. McFadden confirmed her belief that the unauthorized
37
expenses should be paid from Board travel funds allocated for her travel. Superintendent Davis notified Mrs.
McFadden by letter dated 9/12/22 of her responsibility to reimburse the District on or before 10/10/22 for the
unauthorized charges in the amount of $425. Mrs. McFadden reimbursed the District on 10/19/22 for the
unauthorized expenses after a delay of nine days.
Another attempt by Mrs. McFadden to utilize Board travel funds for non-Board business occurred in September
2022 when Mrs. McFadden sought to attend a T.D. Jakes “Woman Thou Art Loosed” event in Atlanta, Georgia.
Rightfully, Superintendent Davis denied the use of District funds to attend this event by Mrs. McFadden
because it was unrelated to Board business. If Superintendent Davis had approved the use of District funds, it
would have been a misuse to taxpayer dollars entrusted to his care.

G. Board Transparency - Circumvention of FOIA

1. Use of personal email - Board business

On several occasions, at least four Board members were included in email exchanges initiated by individual
Board members. While Board Policy BEDC established that a quorum consisted of five members, SC Code of
Laws §30-4-20 (e), provided that a simple majority of the Board, i.e., four members of the seven-member
Board, constituted a quorum, and per §30-4-20 (d) “a meeting exists where there is a quorum of the constituent
membership of the public body, whether corporal or by means of electronic equipment.” These emails sent by
Board members that included four Board members violated the FOIA’s open meeting provisions.
Among the numerous examples identified by the SIG were six emails sent by Mrs. McFadden in September
2022. Mrs. McFadden’s recipients included Mr. Manning, Mrs. Agostini and Dr. Scott. Two emails were sent
on 9/2/22, one on 9/12/22, and two were sent on 9/29/22. The superintendent stated that prior to these emails
being sent he notified Mrs. McFadden the emails created a quorum for the Board under FOIA.
On 9/28/22, Mrs. McKie, cognizant of this concern, forwarded an email to the SIG that she sent as a response to
a constituent. However, she noted in her email to the SIG, “I blind copied our Board members, so as not to
create a quorum/meeting of Board members.” Members advised that they had been trained to use blind-copied
emails. A South Carolina School Boards Association official advised that it did not recommend the use of
blind-copied emails. A First Amendment/FOIA attorney advised that blind-copied emails are treated no
differently than directed or copied emails under FOIA.
The SIG determined that blind-copied emails should conform to the FOIA’s open meeting requirements.
On 2/26/22, Dr. Scott replied to Mr. Manning’s response to a constituent email. Dr. Scott copied all Board
members. On 2/28/22, Mr. Manning responded to her email and included all Board members, noting: “I am
replying to all in like manner to your response to me.”
The SIG assessed the Board members were cognizant, and duly informed, of the FOIA provisions regarding
what constituted a quorum prior to the issuance of these emails to Board members.
The SIG observed that Dr. Holmes and Dr. Scott used personal email accounts during the period of this review
instead of District email accounts while acting in the capacity as a Board member, including communications
with other Board members, district administration, and constituents.
Dr. Holmes used the email address of docholmesschoolboard2@gmail.com and Dr. Scott used the email address
of puttingstudentsfirst2012@gmail.com. Neither email address was housed on District servers. Dr. Holmes
advised that she adopted a District address after she learned that use of a personal address was inconsistent with
FOIA. Emails by Board members regarding District business are public records under FOIA. The

38
commingling of District-related emails with personal emails is inconsistent with the FOIA and should use a
District email address for archival purposes.
2. Use of personal cell phone - Board and District business
The SIG examined Board member text messages and learned that Board members did not use District cell
phones but instead used their personal cell phones for Board communications. As with emails, text messages
related to District business are public records under FOIA. The SIG identified instances where at least four
Board members participated in text message exchanges concerning District business, including text messages
initiated by Mr. Manning (current Board chair) and Dr. Holmes (immediate past Board chair).
The SIG noted that a Dr. Holmes’ text on 8/14/21 canvassed her Group of Four Board members, and asked, “Is
4 good on Monday for our meeting?” As noted on the 8/16/21 Board agenda, this Special Called Meeting
related to advice regarding a legislative proviso. Dr. Holmes excluded those Board members not typically
aligned with her in this text message.

H. Board – Community Relations

1. Taking the Oath of Office prior to filing Statement of Economic Interest

On 11/10/18, Dr. Holmes and Mrs. McKie took their oaths of office prior to filing their Statements of Economic
Interest (SEI).
The SIG sought and received an opinion from the South Carolina Office of the Attorney General (Attorney
General) regarding the effect of a failure by a school board member to timely file an SEI. The Attorney
General’s Office opined 12 that a court may find the failure to timely file an SEI as sufficient cause for removal
if the board’s enabling legislation or some other authority allowed for removal. In addition, “a quo warranto or
declaratory judgement action brought by an appropriate party could result in a court determination that such an
individual is ineligible to hold office and must be removed.” The Attorney General further opined that an
officer serves as a de facto officer until removed, and any actions taken as to the public or third parties would be
valid unless and until a court declares such acts void or removes the officer from office. (See Appendix K)

This was a common complaint voiced by a District constituent shortly after the 2018 general election through
the present. The constituent neither sought an opinion from the Attorney General nor a declaratory judgement
by a court on the matter. An ethics complaint was filed by a District constituent against Dr. Holmes and Mrs.
McKie, which they addressed with the State Ethics Commission.
2. Public participation at Board meetings
Policy BEDH provided for public participation at Board meetings. Consistent with court rulings, the Board
limited speakers during the public participation of Board meetings to three minutes and to issues over which the
Board has jurisdiction. The policy provided, inter alia, that:
• “…[C]omments from the public should not include gossip, defamatory words, or abusive and
vulgar language.”
• “The board will not permit in public session any expression of personal complaints about
individual school personnel or any other person connected with the school system.”

12
Assistant Attorney General Cydney Milling letter to Inspector General Brian D. Lamkin, 10/11/22.

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Prior to the public participation portion of Board meetings, then-chairperson Dr. Holmes read a preamble
regarding the rules for speakers. For example, on 10/12/21, Dr. Holmes read:
“Each person is limited to three minutes, and that our meetings are streamed live and
recorded. Speakers must refrain from using inappropriate language and engaging in any
form of personal abuse or attacks and must not refer to any student or employee by name.
Questions asked during the public participation typically will be referred to the staff
members for response at a later time. Additionally, [under] the guidelines a member of the
public may address the board on any subject within board authority.”
During the 10/12/21 meeting, then-chairperson Dr. Holmes interrupted at least three speakers. Speaker 1 was
interrupted when he/she stated, “I know you’re smiling Ms. Holmes.” Dr. Holmes stated, “We will not call
names.” Speaker 1 apologized to Dr. Holmes by name, to which she responded, “No problem.” Dr. Holmes
interrupted Speaker 2 when he/she stated Dr. Holmes failed to respond to an email. Speaker 2 was not
interrupted when referring to Superintendent Davis. Other speakers were not interrupted at all.

Speaker 3 attempted to read from a 9/16/21 Voice newspaper article’s comment section from a contributor
identified as Dr. Holmes. The comments purportedly made by Dr. Holmes included references to the Speaker 3
as a racist. Dr. Holmes interrupted Speaker 3 and stated, “The Board has no jurisdiction on that part.” Dr.
Holmes interrupted Speaker 3 again at 28:15 and at 28:38 of the Board meeting when he/she read additional
material from the newspaper article for the same reason. At 29:09 of the Board meeting, Dr. Scott attempted to
make a point of order, which was dismissed by Dr. Holmes. At 30:02 of the Board meeting, Mrs. Agostini
attempted to make a point of order that was dismissed by Dr. Holmes. At 30:19, Dr. Holmes called for security
to remove Speaker 3 from the Board podium.

The SIG contacted a well-respected, nationally known parliamentarian who advised that Mrs. Agostini and Dr.
Scott should have been permitted to articulate their points of order. The parliamentarian stated that, in this
instance, Dr. Holmes was unhelpful and should have ruled on the points of order and should not have taken the
objections personally.

A well-respected First Amendment attorney reviewed policy BEDH and viewed a video of the 10/12/21
proceedings at the SIG’s request. The attorney opined as follows:

• The preamble was inconsistent with Board policy BEDH.

• Dr. Holmes’ rulings limiting the speech of Speakers 1, 2, and 3 were inconsistent with the
preamble and policy BEDH.
• Dr. Holmes’ rulings limiting the speech of Speakers 1, 2, and 3 were unconstitutional in limiting
protected speech.
• Speaker 3 read Dr. Holmes’ comments from a newspaper, which she made as a Trustee and
involved Speaker 3’s interest in school district matters. The attorney believed Speaker 3’s
comments to be constitutionally protected speech relevant to the activities of the Board and
should have been permitted.

In addition, Dr. Holmes barred a member of the public from a Facebook page where she held herself out as “Dr.
Teresa Holmes: School Board Member Richland Two” and “Your school board member on the move.” The
attorney opined barring the member of the public was likely a violation of the First Amendment’s guarantee of
the right to receive information.

40
 3. Trespass Notice - Removal from public participation
On 1/25/22 prior to the start of the Board meeting, two District residents were removed from the meeting room
and were subsequently issued notices of trespass pursuant to South Carolina Code of Laws §16-11-620. The
Director of Safety and Security ordered their removal following an incident involving the Dr. Davis’ wife
pursuant to authority delegated in Board Policy AR KI-R, “Visitors.” The policy provided that:

“District and school administrators, after school or after hours program managers, district
security and safety staff, school resource officers or other on-duty, or extra-duty law
enforcement officers assigned to work at a school or event may issue a verbal or written ‘no
trespass’ notice for the school facility, delay the entry of a person for cause, or ask for the
removal [of] any such individual as necessary.”

Administrative rule AR KI-R did not identify procedures for implementing a trespass notice, the length of time
the trespass notice was to be in effect, or due process safeguards, including supervisory review or a definition of
the necessity standard.

The two persons that received trespass letters issued on 1/26/22 were barred from all District property, absent
specific approval for limited purposes, until 6/30/22. The Board considered their appeals though the individuals
were not permitted to personally present their appeals to the Board.

South Carolina Code of Laws §16-11-620 provides:

Any person who, without legal cause or good excuse, enters into the dwelling house, place of
business, or on the premises of another person after having been warned not to do so or any
person who, having entered into the dwelling house, place of business, or on the premises of
another person without having been warned fails and refuses, without good cause or good
excuse, to leave immediately upon being ordered or requested to do so by the person in
possession or his agent or representative shall, on conviction, be fined not more than two
hundred dollars or be imprisoned for not more than thirty days.

The SIG identified the use of several other notices of trespass issued by the Safety and Security Director and
principals. Per SC Code of Laws §16-11-530, “For the purpose of determining … whether or not there has been
a trespass upon such property as this offense is defined in Section 16-11-600 and for all prosecutions under
these penal statutes and other statutes of a like nature, the trustees of the respective school districts in this State
in their official capacity shall be deemed to be the owners and possessors of all school property. [Emphasis
added]”

South Carolina Attorney General Opinion WL 2369068 (2019) stated,

“Section 16-11-620 establishes the misdemeanor of trespass for a person who enters premises
after being warned not to ‘without legal cause or good excuse.’ It contemplates that persons
placed on trespass notice might have the legal right or good cause to come on particular
premises even after receiving that notice. Conversely, ‘South Carolina’s FOIA was designed
to guarantee the public reasonable access to certain activities of the government.’…. The open
meeting requirement in Section 30-4-50 is an integral component of that design…. Further,
the general Assembly instructed that the FOIA ‘must be construed so as to make it possible for
citizens, or their representatives, to learn and report fully the activities of their public officials
at a minimum cost or delay to persons seeking access to public documents or meetings.’” In
addition, the FOIA’s §30-4-70 (d) provides – with respect to a public meeting on public
41
 property -- that “This chapter does not prohibit the removal of any person who wilfully [sic]
disrupts a meeting to the extent that orderly conduct of the meeting is seriously compromised.”

As a result, the Attorney General concluded a court would likely find that a person would have legal cause or
good excuse to attend an open meeting of the school board, even though that person had been placed on a
general trespass notice barring that person’s presence on school property.

4. Lack of transparency in Board communications

While Board members generally acknowledged they worked for their constituent taxpayers, Board member
behavior was often inconsistent with transparency and respect for the public.
For example, on 8/16/21, following executive session in which the Board received legal advice regarding
Proviso 1.108, Mr. Manning moved that the Board “authorize the District to engage legal counsel to provide the
best option and legal strategy to address appropriations budget proviso 1.108, including consulting with
Richland County Council with regard to protecting the health, safety, and well-being of our students and
employees.” Mrs. McKie seconded the motion.
In discussion, Mrs. Agostini, who was unable to attend the executive session and had telephonically joined the
meeting, asked for background on what the Board intended to do with the motion. Dr. Holmes told Mrs.
Agostini that she could not discuss the purpose of the motion because it was discussed in executive session.
Mrs. Agostini asked, “So you’re not going to let the public know what the intent is with hiring lawyers?” Dr.
Holmes told Mrs. Agostini she would be told following the conclusion of the meeting. The motion passed 6-1,
with Mrs. Agostini voting, ‘No.’
The SIG noted that the minutes of the special called meeting on 8/16/21 did not articulate the motion, only that
a motion was made and passed.
On 8/20/21, without a vote authorizing the filing of a lawsuit, the District filed a cause of action with the South
Carolina Supreme Court seeking a temporary injunction to enjoin enforcement of Proviso 1.108. SC Code of
Laws §30-4-70 (b) provides, “The members of a public body may not commit the public body to a course of
action by a polling of members in executive session.”
Mr. Manning advised the SIG that attorneys in executive session recommended the Board not tip their hand
about their plan to file the lawsuit. The SIG determined the Board lacked transparency in failing to describe in
the motion its true purpose, and that its true purpose was wrongly determined in executive session.
Derogatory comments about District constituent and Board members
The SIG identified text messages among a group of Board members (Holmes, McKie and Caution-Parker)
replete with derogatory and defamatory comments of fellow Board members and a constituent between April –
June 2021. In one instance, on 4/12/21 at 14:59 (2:59 p.m.) one Board member referred to a constituent as,
“…his captain of the redneck white supremacists army self hadn’t earned ANYBODY’S advanced degree.” In
another instance on 6/1/21 at 14:53 (2:53 p.m.), one Board member referred to two fellow Board members as
engaging in “racist” associations.
Board member discussion of deleting text messages
On 6/11/21 at 16:15 (3:15 p.m.), one Board member asked the group, “Think we should tell La to erase texts?”
The topic of deleting text messages is repeated on 10/11/21 beginning at 14:51 (2:51 p.m.), through 16:34 (3:34
p.m.). Specifically, one Board member texted, “I delete daily after conversations” to which Dr. Holmes
replied, “Will do.” Dr. Holmes was the Board chair at the time of this text message exchange.
42
Board member discussion of parental involvement
The SIG identified derisive comments among Board member text messages. This was especially true in a group
text message among Board members McKie, Manning, Caution-Parker and Holmes for the period of 6/14/22 –
8/5/22.
An example of the Board members’ disregard for the parents of District students occurred on 6/16/22 and the
inaction of safety and security ad hoc committee chaired by Board member Scott. At 8:17 on 6/16/22, Dr.
Holmes group messaged:
“That's why I said in Exec. Let's just push forward. We do not need parents to decide. I think to let
them fill [sic] involved we simply hold a parent only input meeting no committee members from
them. That way they all were heard but we are moving on.”

I. Summary of Individual Board Members

All previously identified violations of Board policies are incorporated herein.

1. Mrs. Lashonda McFadden

Mrs. McFadden’s Board term does not expire until November 2024.

Potential Ethics Violation and District Indebtedness

As of 10/20/22, Mrs. McFadden is currently indebted to the District for $2,497.70, which is comprised of
$1,902.75 for school meal debt and $594.95 for other school-related fees for her children. An additional $836
in future magnet field study fees is not included in the current outstanding debt to the District.

On 8/23/22 at special called Board meeting, Mrs. McFadden advocated for the forgiveness of meal debt for
District parents knowing that she owed school meal debt dating back to May 2017. By doing so, Mrs.
McFadden potentially violated state ethics law [SC Code of Laws, §8-13-700(B)] that prohibits a public official
from utilizing their office to influence a governmental decision in which “he, a family member…has an
economic interest.” Mrs. McFadden failed to recuse herself from the special called meeting whose sole purpose
was to address school meal debt in the District.

Circumvention of Internal Controls

As previously set forth, Mrs. McFadden failed to reimburse the District in a timely manner for unused travel
advance funds issued in January 2022 for travel that was cancelled. After repeated communications (email and
written) from the superintendent to Mrs. McFadden the unused funds were reimbursed after 56 days. Again, in
September and October 2022, the superintendent and Chairman Manning issued numerous communications to
Mrs. McFadden for repayment of $425 in personal expenses incurred during a Board trip to Atlanta, Georgia,
that were not authorized by the District or the Board. Mrs. McFadden engaged in back and forth discussions
with Chairman Manning and the superintendent about applying District budgeted funds to retire this debt. On
10/18/222, after Chairman Manning’s pronouncement to Mrs. McFadden that her request to utilize Board travel
funds for this purpose potentially violated state ethics law [SC Code of Laws, §8-13-700(A)] did she repay the
District the $425 in personal expenditures.

43
Public confrontations

As previously set forth, on 12/8/21, Mrs. McFadden physically presented herself at the R2i2 District offices
issuing demands to the staff for the superintendent to speak with her. The SIG interviewed numerous District
staff who expressed concerns for their personal safety due to Mrs. McFadden’s behavior and verbal
confrontations. As a result, the superintendent’s personal attorney issued a letter to Mrs. McFadden stating that
she was to have no contact with the superintendent outside of a Board meeting.

Circumvention of FOIA through email communications

A review of Board member emails identified Mrs. McFadden’s repeated use of District email for Board
business with four or more Board members on each email. SC Code of Laws, §30-4-20(e) states that a quorum
is a simple majority of membership of the public body, which in this matter is four members. The SIG noted
the review did not identify Board action was taken on any given subject; nonetheless, Mrs. McFadden
frequently advocated her position on Board issues that was consistent with open debate at a public Board
meeting. Mrs. McFadden was not the only Board member who engaged four or more members through District
and personal email communications on Board matters in violations of FOIA, but she was the most prolific.

Among the other misuses of the District email system, Mrs. McFadden:

• Made an unauthorized disclosure of attorney-client privileged communication on 9/9/22

regarding a personnel matter that was under appeal before the Board.
• Made repeated demands for information from the superintendent with threats of poor job
performance evaluations and attacks on the superintendent’s integrity.

2. Dr. Monica E. Scott

Dr. Scott’s Board term does not expire until November 2024.

3. Mrs. Amelia McKie

Mrs. McKie’s Board term expires in November 2022 and she is not seeking reelection to her Board seat.

The State Ethics Commission (Ethics Commission) fined Mrs. McKie for failure to file a Statement of
Economic Interest prior to taking here oath of office in 2018. Mrs. McKie settled this matter with the Ethics
Commission.

A review of the South Carolina Ethics Commission website identified $57,000 in fines and associated penalties
were assessed against Mrs. McKie for failure to file timely campaign reports and filings. Mrs. McKie has
addressed her personal debt and is currently on a payment plan to repay the fines and penalties.

4. Dr. Teresa Holmes

Dr. Holmes’ Board term expires in November 2022 and she is seeking reelection to her Board seat.

Dr. Holmes was a participant in the events of the 4/28/22 executive session. As the Board chair during the
executive session, Dr. Holmes violated numerous Board policies to include the failure to admonish Mr.
Manning for the surreptitious recording of the meeting. This led to a breach of trust among the Board members
and adversely impacted the work of the Board.

44
In addition to the prior violations of Board policies by Dr. Holmes, the Ethics Commission fined Dr. Holmes for
failure to file a Statement of Economic Interest prior to taking her oath of office in 2018. Dr. Holmes settled
this matter with the Ethics Commission.

5. Mr. James Manning

Mr. Manning’s Board term expires in November 2022 and he is not seeking reelection to his Board seat.

In addition to the surreptitious recording of Board meeting executive session on 4/28/22 which violated Board
Policy BC, Mr. Manning also violated Board policies BC, BCA, and BEC when he disclosed information that
was discussed in a September 2022 Board meeting executive session. According to a confidential, reliable
source, Mr. Manning disclosed to a former District employee that the District entered into a settlement with a
former school administrator.

6. Dr. Cheryl Caution-Parker

Dr. Caution-Parker’s Board term expires in November 2022 and she is not seeking reelection to her Board seat.

7. Mrs. Lindsay Agostini

Mrs. Agostini’s Board term does not expire until November 2024.

J. Findings and Recommendations – Board of Trustees

Finding #BoT-1: Board dysfunction and member conduct fostered a hostile environment, which created
reputational, operational, and legal risk and harmed District operations, fiscal affairs, and human capital
management.

Recommendation #BoT-1: The SIG recommends that Board members receive training on Board
policy.
Finding #BoT-2: Board members periodically violated BHC “Board/Staff Communication” that stated, the
Board “will make all official communications, policies, and directives of staff interest and concern to the staff
through the superintendent.”

Recommendation #BoT-2: Board members should adhere to all Board policies, in particular Board
Policy BHC when individual Board members have requests for information.

Finding #BoT-3: During the period of this investigation, three Board members requested and received travel
advances for Board related travel, some of which exceeded actual reimbursable expenses incurred. Beginning
with the 2022-23 school year the District assigned individual account numbers to the Board members to track
Board travel. On 10/25/22, the Board revised Policy BID “Board Member Compensation and Expenses”
ending the practice of Board members receiving travel advances and suspended a Board member’s ability to
travel until any outstanding travel balance is paid back to the District.

Recommendation #BoT-3: The SIG recommends reimbursements to Board members for Board travel
be processed within ten business days following receipt by the District of proper documentation.

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Finding #BoT-4: Board member Lashonda McFadden violated Policy DKC and circumvented District internal
controls that caused the District to be charged for unauthorized lodging expenses during the period 9/7/22
through 9/10/22.

Recommendation #BoT-4: The SIG recommends the District establish safeguards to ensure expenses
above the District authorized travel expenses are unable to be charged against the District P-Card.

Finding #BoT-5: The SIG determined Dr. Holmes and Dr. Scott utilized personal email accounts instead of
District email accounts for emails relating to matters over which the Board had supervision, control,
jurisdiction, or advisory power in a manner inconsistent with the FOIA. The SIG confirmed that Dr. Holmes
began utilizing her District email once this matter was brought to her attention.
Recommendation #BoT-5: The SIG recommends a revision to Policy BEDL Board Members and
Electronic Communications to include the requirement for all Board members to utilize District email
accounts for all communication related to matters over which the Board had supervision, control,
jurisdiction, or advisory power.
Finding #BoT-6: The SIG determined Board members used personal phones to communicate about matters
over which the Board had supervision, control, jurisdiction, or advisory power by text.
Recommendation #BoT-6: The SIG recommends the District revise Policy BEDN Board Members’
Use of District-Owned Portable Devices to note that each Board member will be provided (rather than
offered), a portable device(s), including a cell phone, to be used for all official Board communication,
especially emails and texts, and will be returned at the end of the Board member’s term of office.

Finding #BoT-7: Administrative Rule (AR) KI-R did not identify procedures for implementing a trespass
notice, the length of time of the no-trespass restriction, or due process safeguards, including supervisory review
or a definition of the necessity standard.

Recommendation #BoT-7a: The SIG recommends the District revise AR KI-R to include legal review,
especially in relation to due process provisions and the length of time of the no-trespass restriction.

Recommendation #BoT-7b: The SIG recommends the District use remedies under FOIA when the
orderly conduct of a meeting is seriously compromised.

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 VII. Conclusion
The question remains, “What, if anything, did the Board undertake to keep “the main thing, the main thing?” as
one Board member remarked to the SIG.

The SIG’s analysis of the Board’s focus on academic and non-academic matters over the last four school years
identified only 14.2% [SIG emphasis] of the Board’s agenda items were on academic matters. More important,
the Board addressed only five academic items over the last two school years when Board member acrimony and
disruptive communications directed toward the superintendent, District staff and the public were the greatest.

Regardless, the District delivered quality public education to more than 112,837 students over the four-year
period under review. The academic achievements and test scores, while rebounding from disruptions due to
COVID-19, still have room for improvement. This is where a unified Board focused on academic achievement
and supportive of the superintendent and District staff can have its greatest impact. To do anything else is a
disservice to the students, parents and taxpayers of the District.

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 Compilation of Findings and Recommendations

District Operations

Finding #DO-1: The District’s five-year strategic plan that included the 2021-22 school year contained goals
that were neither specific, measurable, nor time bound. The SIG determined the District initiated a
comprehensive strategic planning process for the new five-year strategic plan set to commence with the 2023-
24 school year that will address specific goals and measurable outcomes. No further action recommended.

Finding #DO-2: The District did not identify a District administrative rule or Board policy adopting the
student discipline guidelines table.
Recommendation #DO-2: The SIG recommends that a student discipline table be incorporated into an
existing District administrative rule or Board policy.

Fiscal Affairs
Finding #FA-1: The District failed to identify it sought and received a written opinion from the Division of
Procurement Services that its procurement code was substantially similar to the Consolidated Procurement
Code per SC Code of Laws §11-35-5340. The SIG confirmed this with the Division of Procurement Services.
Recommendation #FA-1: The SIG recommends the District adopt the 2021 Model School District
Procurement Code or submit the District’s procurement code to the Division of Procurement Services
for a written opinion as required by SC Code of Laws, §11-35-5340.
Finding #FA-2: The District did not comply with the SC Code of Regulations 19–445.2165 (A) and (B) when
it executed a contract with Service Solutions after receiving the promise of gifts, such as student scholarships
and donations.
Recommendation #FA-2: The District should ensure that procurement officers review responses to all
requests for proposals to ensure compliance with the SC Code of Regulations 19–445.2165 (A) and (B)
and not accept gifts, such as student scholarships and donations, either directly or indirectly from current
or potential contractors in order to avoid the appearance of influence in a contract award.
Finding #FA-3: The District did not identify a Procurement Card Policy.
Recommendation #FA-3a: The SIG recommends the District implement a Procurement Card policy
that is substantially similar to the “South Carolina Purchasing Card Policy and Procedures” published on
the Division of Procurement Services website.
Recommendation #FA-3b: The SIG recommends the District audit the P-Card transactions identified
in Table B and determine the purpose of items 1, 3, 4, and 5 and the expenditure of funds in support of
District program, and report the results of the audit to the SIG by 3/31/23.
Finding #FA-4: The District maintained a checkbook in the HR department to pay for SLED background
checks of employee candidates. The use of the checkbook violated District policies DGA and DK by using the
signatures of HR staff on these checks instead of the District superintendent and chief financial officer. The
SIG’s review of the accounting records for this account did not find evidence of misuse of funds; however, the
use of the checkbook outside of the Finance department’s authority created an internal control deficiency and
elevated the risk for fraud. The District took immediate action and removed the checkbook from the HR

48
department and closed the account when the matter was brought to District leadership’s attention. This matter
has been addressed. No further action is required.
Finding #FA-5: The District’s relationship with the Foundation was not governed by an operating agreement or
Memorandum of Understanding (MOU) that governed the Foundation’s use of District resources and personnel.
As a result, the District and the Foundation lacked sufficient internal controls and processes that resulted in the
Foundation depositing monies and federal grant funds intended for the District into a Foundation bank account.
Recommendation #FA-5: The District should develop an operating agreement or MOU with the
Foundation that sets forth the Foundation’s roles and responsibilities in the use of District resources and
personnel.
Finding #FA-6: Federal grant funds in the amount of $625,000 that were awarded to the District were diverted
into a Foundation account, which excluded the $625,000 from the District’s annual audits. Consequently, HHS
misdirected the reimbursement of District expenditures to the Foundation’s bank account instead of the
District’s bank account. The Foundation delayed repayment of the federal grant funds to the District because no
mechanism had been established between the District and the Foundation to facilitate the transfer of funds. In
addition, the SIG identified at least 35 checks payable to the District totaling $138,575.44 were deposited into a
Foundation bank account.
Recommendation #FA-6: The District should adopt internal controls and processes with the
Foundation to ensure that funds intended for the District are deposited into a District account.
Finding #FA-7: The District did not make a determination and assessment of the Foundation as a component
unit for its external auditors as defined in Statement No. 14 of the Governmental Accounting Standards Board
(GASB).
Recommendation #FA-7: The SIG recommends the District conduct and assessment of the Foundation
and seek a professional opinion from its external auditors to determine if the Foundation should be
disclosed as a component unit of the District.
Finding #FA-8: The SIG determined the Foundation utilized commingled funds when it reported a $168,776
loss in gross receipts that included $81,337.42 of federal grant funds awarded to the District, not the
Foundation. The $81,337.42 in federal grant funds supported the Foundation’s application for and subsequent
receipt of $50,000 in SC CARES Act funds. The Foundation issued a check for $50,000 to the Central Carolina
Community Foundation on 12/31/22 that did not go to the benefit of the District. The SIG further determined
the Foundation utilized $9,500 in commingled District funds to conduct a public opinion survey regarding a
2018 bond referendum.
Recommendation #FA-8: The SIG will refer the receipt of SC CARES Act funding by the Foundation
to the South Carolina Office of the Attorney General, which has jurisdiction over nonprofit corporations
for investigation of the Foundation’s tax-exempt status and the receipt of the SC CARES Act funds.
Finding #FA-9: The District did not have an internal auditor position or function to conduct fiscal and program
assessments for District leadership and the Board of Trustees.
Recommendation #FA-9: The SIG recommends implementing an internal audit program.

Human Capital
Finding #HC-1: The District spent nearly $2.5 million over the last four years in payment to vendors to
acquire international teachers who were limited to five years of employment with the District.
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 Recommendation #HC-1: The SIG recommends the District consider utilizing bonuses to retain and
recruit teachers to work in the District.
Finding #HC-2: The District established the Premier 100 initiative to recruit and retain 100 men of color by
2024 and paid for professional development training and related expenses, including dinners, speakers, and field
trips, as well as stipends to these teachers. The District terminated the distribution of stipends to Premier 100
participants and opened the professional development opportunities provided by Premier 100 to all District
employees. No further action is required.
Finding #HC-3: The HR department lacked standard operating procedures for daily HR processes and a
comprehensive payroll policy manual that resulted in inconsistences in salary computations based on position
and/or experience, which adversely affected various HR functions and payroll functions in the Finance
department.
Recommendation #HC-3a: The SIG recommends the District HR department establish standard
operating procedures for daily processes and a payroll policy manual to ensure consistency in salary
computations.
Recommendation #HC-3b: The SIG recommends the District engage an external organizational
management group to conduct a comprehensive study of the HR department’s processes to identify
inefficiencies and strategies for improvement.
Finding #HC-4: The District conducted an audit of onboard teacher payroll for the period of 2012 – 2022 that
identified underpayments totaling $459,381 related to certification changes and step increases. Retroactive
payments were made to the onboard employees between February 2022 and October 2022.
Recommendation #HC-4: The District should ensure teacher payroll audits are conducted annually to
ensure accuracy in teacher certifications, experience and step increases.

Finding #HC-5: The HR department was delinquent in processing payroll data of 190 employees resulting in
late payments for paychecks scheduled for 8/15/22, in part due to inadequate staffing.

Recommendation #HC-5a: The SIG recommends cross-training HR personnel to ensure timely data
processing of new hires during the summer hiring season.

Recommendation #HC-5b: The SIG recommends an increase of four HR specialist positions in HR

department.

Finding #HC-6: The HR department is responsible for investigating employee misconduct and conducting a
case review, which creates a risk of investigative bias in determining disciplinary action, if any. The SIG
determined the officials who conducted the misconduct investigations had limited investigative training and
experience. A recent employee misconduct investigation was poorly documented and contained exculpatory
information and conflicting witness statements. The District failed to provide the exculpatory witness
statements to the employee in support of the employee’s appeal of the disciplinary finding.

Recommendation #HC-6: The SIG recommends the District separate the investigative process from
the case review process that includes a legal review of the investigative results to mitigate the risk and
appearance of investigative bias in determining disciplinary action, if any.

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Finding #HC-7: The District did not have a unified district-wide time and attendance system to track
compensatory time and compensatory time off.

Recommendation #HC-7: The SIG recommends the District establish a unified district-wide time and
attendance system, the purposes of which would include tracking compensatory time and compensatory
time off.

Board of Trustees

Finding #BoT-1: Board dysfunction and member conduct fostered a hostile environment, which created
reputational, operational, and legal risk and harmed District operations, fiscal affairs, and human capital
management.

Recommendation #BoT-1: The SIG recommends that Board members receive training on Board
policy.
Finding #BoT-2: Board members periodically violated BHC “Board/Staff Communication” that stated, the
Board “will make all official communications, policies, and directives of staff interest and concern to the staff
through the superintendent.”

Recommendation #BoT-2: Board members should adhere to all Board policies, in particular Board
Policy BHC when individual Board members have requests for information.

Finding #BoT-3: During the period of this investigation, three Board members requested and received travel
advances for Board related travel, some of which exceeded actual reimbursable expenses incurred. Beginning
with the 2022-23 school year the District assigned individual account numbers to the Board members to track
Board travel. On 10/25/22, the Board revised Policy BID “Board Member Compensation and Expenses”
ending the practice of Board members receiving travel advances and suspended a Board member’s ability to
travel until any outstanding travel balance is paid back to the District.

Recommendation #BoT-3: The SIG recommends reimbursements to Board members for Board travel
be processed within ten business days following receipt by the District of proper documentation.

Finding #BoT-4: Board member Lashonda McFadden violated Policy DKC and circumvented District internal
controls that caused the District to be charged for unauthorized lodging expenses during the period 9/7/22
through 9/10/22.

Recommendation #BoT-4: The SIG recommends the District establish safeguards to ensure expenses
above the District authorized travel expenses are unable to be charged against the District P-Card.

Finding #BoT-5: The SIG determined Dr. Holmes and Dr. Scott utilized personal email accounts instead of
District email accounts for emails relating to matters over which the Board had supervision, control,
jurisdiction, or advisory power in a manner inconsistent with the FOIA. The SIG confirmed that Dr. Holmes
began utilizing her District email once this matter was brought to her attention.
Recommendation #BoT-5: The SIG recommends a revision to Policy-BEDL Board Members and
Electronic Communications to include the requirement for all Board members to utilize District email
accounts for all communication related to matters over which the Board had supervision, control,
jurisdiction, or advisory power.

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Finding #BoT-6: The SIG determined Board members used personal phones to communicate about matters
over which the Board had supervision, control, jurisdiction, or advisory power by text.
Recommendation #BoT-6: The SIG recommends the District revise Policy BEDN Board Members’
Use of District-Owned Portable Devices to note that each Board member will be provided (rather than
offered), a portable device(s), including a cell phone, to be used for all official Board communication,
especially emails and texts, and will be returned at the end of the Board member’s term of office.

Finding #BoT-7: Administrative Rule (AR) KI-R did not identify procedures for implementing a trespass
notice, the length of time of the no-trespass restriction, or due process safeguards, including supervisory review
or a definition of the necessity standard.

Recommendation #BoT-7a: The SIG recommends the District revise AR KI-R to include legal review,
especially in relation to due process provisions and the length of time of the no-trespass restriction.

Recommendation #BoT-7b: The SIG recommends the District use remedies under FOIA when the
orderly conduct of a meeting is seriously compromised.

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 List of Appendices
A. Letter for Governor Henry McMaster to Inspector General Brian D. Lamkin requesting the initiation of
an investigation into the Richland School District Two (District) and its Board of Trustees (Board),
dated 6/22/22.

B. District Strategic Plan - Pathway to Premier

C. District Procurement Code (2006)

D. 2021 Model School District Procurement Code

E. Service Solutions Proposal/Contract

F. District Financial Operations Procedure Manual

G. Richland School District Two Foundation Articles of Incorporation and Bylaws

H. District HR Department Anthology of Pay Policies

I. Consultant report of Board members

J. Board – District Organizational Chart

K. South Carolina Attorney General’s Opinion – dated 10/11/22

L. Transcript of 4-28-22 Board Meeting Executive Session

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